Finding 1124661 (2024-002)

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Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: Effort reports for federal awards were certified significantly late, averaging 208 days overdue, violating internal policy timelines.
  • Impacted Requirements: Compliance with 2 CFR 200.430 for timely effort certification is not being met, risking inaccuracies in compensation costs charged to federal awards.
  • Recommended Follow-up: Recommunicate the effort certification policy and provide training to ensure all staff understand and meet timely certification expectations.

Finding Text

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.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $3.19M
17.720 Disability Employment Policy Development $1.05M
93.969 Pphf Geriatric Education Centers $914,313
17.268 H-1b Job Training Grants $840,402
93.087 Enhance Safety of Children Affected by Substance Abuse $787,352
93.788 Opioid Str $744,673
93.800 Organized Approaches to Increase Colorectal Cancer Screening $686,821
93.069 Public Health Emergency Preparedness $653,662
93.186 National Research Service Award in Primary Care Medicine $625,462
93.307 Minority Health and Health Disparities Research $570,661
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $463,310
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $400,226
93.958 Block Grants for Community Mental Health Services $376,504
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $357,751
93.213 Research and Training in Complementary and Integrative Health $326,712
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $306,282
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $304,399
12.007 Military Health Services Research (mhsr) $298,107
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $289,668
21.027 Coronavirus State and Local Fiscal Recovery Funds $280,206
93.155 Rural Health Research Centers $251,842
93.493 Congressional Directives $250,000
93.850 Improving Epilepsy Programs, Services, and Outcomes Through National Partnerships $246,198
93.127 Emergency Medical Services for Children $230,377
93.U01 Greater Monadnock Regional Public Health Network Services $203,244
93.778 Medical Assistance Program $191,314
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $187,836
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $179,865
93.398 Cancer Research Manpower $169,631
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $161,812
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $153,744
93.268 Immunization Cooperative Agreements $136,332
93.478 Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees $128,779
93.991 Preventive Health and Health Services Block Grant $93,359
93.113 Environmental Health $89,605
93.397 Cancer Centers Support Grants $81,393
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $77,997
93.145 Hiv-Related Training and Technical Assistance $71,324
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $67,536
20.600 State and Community Highway Safety $64,733
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $62,240
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $56,164
93.879 Medical Library Assistance $51,265
93.310 Trans-Nih Research Support $49,873
93.276 Drug-Free Communities Support Program Grants $47,859
16.758 Improving the Investigation and Prosecution of Child Abuse and the Regional and Local Children's Advocacy Centers $45,013
93.838 Lung Diseases Research $34,859
93.837 Cardiovascular Diseases Research $34,234
93.395 Cancer Treatment Research $31,703
93.865 Child Health and Human Development Extramural Research $31,495
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $28,750
93.393 Cancer Cause and Prevention Research $26,804
12.599 Congressionally Directed Assistance $24,472
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $24,342
93.061 Innovations in Applied Public Health Research $23,015
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $22,499
93.110 Maternal and Child Health Federal Consolidated Programs $20,464
93.136 Injury Prevention and Control Research and State and Community Based Programs $20,433
93.866 Aging Research $19,950
93.855 Allergy and Infectious Diseases Research $19,733
93.173 Research Related to Deafness and Communication Disorders $15,838
93.350 National Center for Advancing Translational Sciences $15,412
93.732 Mental and Behavioral Health Education and Training Grants $14,365
10.558 Child and Adult Care Food Program $13,446
93.301 Small Rural Hospital Improvement Grant Program $13,312
93.859 Biomedical Research and Research Training $12,883
93.867 Vision Research $11,697
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $11,466
93.989 International Research and Research Training $10,571
93.059 Training in General, Pediatric, and Public Health Dentistry $9,261
93.959 Block Grants for Prevention and Treatment of Substance Abuse $8,768
93.121 Oral Diseases and Disorders Research $8,016
93.396 Cancer Biology Research $7,389
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $6,273
93.226 Research on Healthcare Costs, Quality and Outcomes $4,077
12.420 Military Medical Research and Development $3,743
10.902 Soil and Water Conservation $3,478
93.761 Evidence-Based Falls Prevention Programs Financed Solely by Prevention and Public Health Funds (pphf) $2,525
93.394 Cancer Detection and Diagnosis Research $1,389
93.242 Mental Health Research Grants $1,230
93.279 Drug Use and Addiction Research Programs $1,055