Finding 1205400 (2024-005)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2026-03-31

AI Summary

  • Core Issue: The Corporation lacks proper internal controls for reviewing and approving expenditures related to federal grant subawards.
  • Impacted Requirements: Failure to comply with Title 2 U.S. Code of Federal Regulations, Part 200.303, which mandates effective internal controls over federal awards.
  • Recommended Follow-Up: Management should improve control designs to ensure documentation of review and approval for all expenditures submitted for reimbursement.

Finding Text

Finding Reference: 2024-005 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Treasury Awards: Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Periods: July 1, 2023 – December 31, 2026 Description: Evidence of Review and Approval of the Reported Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” The major program Assistance Listing 21.027 includes two sub-vendor contracts between the granting agency, Department of Treasury and UMMS for the Baltimore County Public Health Pathways Healthcare Workforce Recovery Program and MONSE HVIP. Condition The Corporation did not have appropriately designed internal controls in place over the grant subawards related to review and approval of the expenditures that were included in the Baltimore County, Maryland submission and the Mayor's Office of Neighborhood Safety and Engagement submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to Baltimore County, Maryland and the Mayor's Office of Neighborhood Safety and Engagement in the required submissions. Effect or potential effect The expenditures included in the Baltimore County, Maryland submission and the Mayor's Office of Neighborhood Safety and Engagement submissions could be unallowed costs, inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context For the Baltimore County Public Health Pathways Healthcare Workforce Recovery Program subaward’s annual financial report submission to Baltimore County, Maryland, management did not retain documentation to evidence review and approval of the stipend expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. For the MONSE HVIP subaward’s monthly financial report submissions to the Mayor's Office of Neighborhood Safety and Engagement, management did not retain documentation to evidence review and approval of the fringe and indirect cost rates and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of the stipends, fringe and indirect cost rates and the expenditures submitted to the Department of Treasury for reimbursement. View of responsible officials There is no disagreement with the audit finding.

Corrective Action Plan

A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the Department of Treasury for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue educating grant managers on capabilities within the system that can be utilized in the execution of review and approval of grant expenditures prior to timely submission to the relevant granting agencies for reimbursement. Centralized repositories have been set up for grant managers to extract specific monthly financial reports for use in the execution of their controls, as well as to retain their review and approval evidence. The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. ORSPA and Corporate Financial Reporting are developing standard operating procedures for the required review and reconciliation of grant expenditures per the accounting system to the financial submissions to the granting agency, including requirements for maintaining evidence of the review(s). Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1205394 2024-001
    Material Weakness Repeat
  • 1205395 2024-002
    Material Weakness Repeat
  • 1205396 2024-003
    Material Weakness Repeat
  • 1205397 2024-004
    Material Weakness Repeat
  • 1205398 2024-004
    Material Weakness Repeat
  • 1205399 2024-005
    Material Weakness Repeat
  • 1205401 2024-006
    Material Weakness Repeat
  • 1205402 2024-006
    Material Weakness Repeat
  • 1205403 2024-007
    Material Weakness Repeat
  • 1205404 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $352,026
21.027 COVID-19 - CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $204,285
16.575 CRIME VICTIM ASSISTANCE $199,999
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $94,247
93.078 STRENGTHENING EMERGENCY CARE DELIVERY IN THE UNITED STATES HEALTHCARE SYSTEM THROUGH HEALTH INFORMATION AND PROMOTION $91,018
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND OTHER SUBSTANCES USE PROGRAM $87,155
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $80,952
16.320 SERVICES FOR TRAFFICKING VICTIMS $60,297
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $32,750
93.354 COVID-19 - PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $30,000
93.325 PARALYSIS RESOURCE CENTER $25,000
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $9,999
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $2,000