Finding 1075295 (2023-003)

Material Weakness
Requirement
ABH
Questioned Costs
-
Year
2023
Accepted
2024-09-27
Audit: 321602
Organization: Bjc Healthcare (MO)

AI Summary

  • Core Issue: Inconsistent retention of Effort Certification Reports (ECRs) review and approval documentation, risking unallowable expenses being charged to federal funds.
  • Impacted Requirements: Compliance with Section 200.303(a) of the Uniform Guidance, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: Management should reinforce internal controls to ensure all ECRs are properly reviewed, approved, and documented consistently.

Finding Text

Finding 2023-003 – A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and H. Period of Performance Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services Federal Program: Research and Development Cluster (Assistance Listing Nos. 93.395 and 93.399) BJC HealthCare Location: Missouri Baptist Medical Center Pass-Through Entities and Award Numbers: Pass-Through Award Periods: Brigham and Women’s Hospital, Inc./120870 (Amendment 1) Brigham and Women’s Hospital, Inc./120870 03/01/2023–02/29/2024 03/01/2022–02/28/2023 Decatur Memorial Hospital/None 08/01/2022–07/31/2023; 08/01/2023–07/31/2024 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Management reviews and approves Effort Certification Reports (ECRs) for allowability and period of performance, including determining whether adjustments were required and appropriate. Evidence of review and approval was not consistently retained for ECRs. Cause: Due to employee turnover, evidence of review and approval over the ECRs by the appropriate Grant Management Office personnel was not consistently retained during the fiscal year. Effect or potential effect: Unallowable expenses could be charged to the Research and Development Cluster program. Questioned costs: None. Context: Total Research and Development Cluster expenditures reported on the schedule of expenditures of federal awards are $1,125,092 for the year ended December 31, 2023. Of this amount, payroll costs totaled $666,648 and fringe benefit costs totaled $184,759. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure that established internal controls over the review and approval of effort reports are consistently followed. Views of responsible officials: BJC agrees with the findings as reported. BJC is committed to complying with program requirements and meeting program objectives as defined in Section 200.303(a) of the Uniform Guidance, regarding auditee internal controls. To facilitate these requirements, BJC will review and strengthen current controls and documentation to ensure that all ECRs are appropriately approved and documentation of the approval is retained.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 498851 2023-001
    Material Weakness Repeat
  • 498852 2023-001
    Material Weakness Repeat
  • 498853 2023-003
    Material Weakness
  • 498854 2023-003
    Material Weakness
  • 498855 2023-002
    Material Weakness Repeat
  • 498856 2023-002
    Material Weakness Repeat
  • 1075293 2023-001
    Material Weakness Repeat
  • 1075294 2023-001
    Material Weakness Repeat
  • 1075296 2023-003
    Material Weakness
  • 1075297 2023-002
    Material Weakness Repeat
  • 1075298 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $15.87M
84.268 Federal Direct Student Loans $5.82M
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $3.36M
93.399 Cancer Control $1.03M
84.063 Federal Pell Grant Program $766,487
93.493 Congressional Directives $575,440
93.788 Opioid Str $473,845
93.889 National Bioterrorism Hospital Preparedness Program $457,610
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $252,140
84.007 Federal Supplemental Educational Opportunity Grants $116,890
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $97,837
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $90,382
93.395 Cancer Treatment Research $67,893
84.425 Covid-19 Education Stabilization Fund $58,704
93.124 Nurse Anesthetist Traineeship $57,038
16.582 Crime Victim Assistance/discretionary Grants $28,887
93.173 Research Related to Deafness and Communication Disorders $12,155
93.671 Covid-19 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $12,152
93.558 Temporary Assistance for Needy Families $12,128
93.732 Covid-19 Mental and Behavioral Health Education and Training Grants $10,237
93.393 Cancer Cause and Prevention Research $8,941
93.397 Cancer Centers Support Grants $3,800
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $2,034
84.033 Federal Work-Study Program $1,943