2024-006 Program: Equitable Sharing Program Federal Financial Assistance Listing Number: 16.922 Federal Grantor: U.S. Department of Justice Award No. and Year: 2024 Compliance Requirements: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: During our testing of the Sheriff Department’s compliance with allowable costs/cost principles requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were miscalculated. Cause: Equitable sharing funds may not be used for salaries, except under certain provisions outlined in Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department calculates the allowable portion of personnel salaries using a separate template that contained a formula error which inaccurately calculated the total salaries costs allocated to the program. The Sheriff’s department did not have internal controls in place to ensure that the allowed salaries were being calculated correctly. However, the error was detected after the 5th out of 6 months in which these types of costs were allocated to the program. Effect: Salary costs were allocated to the program in an incorrect amount. Questioned Costs: Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned costs for the total population was $23,409. Context/Sampling: A sample of forty (40) individuals were selected from a population consisting of (840) payroll transactions. Repeat Finding from Prior Years: No. Recommendation: We recommend the Sheriff’s Department establish and maintain internal controls to ensure the overtime calculations are being accurately allocated to the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.
Cluster: Research and Development (relevant to assistance listing numbers 17.720 and 93.846 below) Sponsoring Agency: Department of Labor, Department of Health and Human Services Award Names: Research and Development- VT RETAIN - Phase 2, Arthritis, Musculoskeletal and Skin Diseases Research Other major programs: H-1B Rural Healthcare Grant Program, Upstream 2: Increasing mental health and trauma identification and referrals for youth ages 12-18 years, Improving Care for Children and Youth in NH with Trauma and Intellectual and Developmental Disabilities (Project TIDD), Project Launch Upper Valley: Promoting a healthy start for young children and their caregivers, Rural Health Outreach and Rural Network Development Program, Substance Abuse & Mental Health Services Administration (SAMHSA) , Community Mental Health Block Grant Award Numbers: 1947RTN2-02, 1R01AR081952-01A, HG-35889-21-60-A-33, 1H79SM084710-01, 1H79SM084906-01, 1H79SM082302-01, 1 GA1RH42907-01-00, SS-2022-OCOM-02-CLINI-01 Assistance Listing Title: Disability Employment Policy Development, Arthritis, Musculoskeletal and Skin Diseases Research, H-1B Job Training Grants, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Rural Health Care Services, Block Grants for Community Mental Health Services Assistance Listing Number: 17.720, 93.846, 17.268, 93.243, 93.912, 93.958 Award Year: 2023-2024 Pass-through entity: Vermont Department of Labor, Not applicable, Not applicable, Not applicable, Not applicable, New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: • Research and development- 7 of 7 selected effort reports totaling $21.4k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 208 days late. • 17.268- 2 of 2 selected effort reports totaling $7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 62 days late. • 93.243- 4 of 4 selected effort reports totaling $5k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 78 days late. • 93.912- 3 of 3 selected effort reports totaling $4.3k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 179 days late. • 93.958- 2 of 4 selected effort reports totaling $17.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. They were on average 189 days late. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to.