Finding 12115 (2022-002)

Finding 2022-002 Identification of the federal program: Federal Grantor: U.S. Department of Health and Human Services Assistance Listing No.: 93.067, Global AIDS Award Number: 5 NU2 GGH001943-04-00 and 6 NU2 GGH001943-05-00 Award Year: 2021?2022 Criteria or specific requirement (including statutory, regulatory, or other citation): 2 CFR 200.303 requires that a 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 and the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act) that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: VUMC is a prime recipient of funding from the Centers for Disease Control and Prevention related to the Global AIDS grant and made first tier subawards of greater than $30,000. VUMC filed a single report in FSRS for the total of all its subawards instead of filing a separate report for each subaward. Cause: Policies and procedures and internal controls were not in place to ensure compliance with the Transparency Act. Effect or potential effect: VUMC did not comply with the Transparency Act and report all required information in FSRS. Questioned costs: $0 Context: VUMC made first tier subawards to 22 subrecipients totaling $3,885,454 in federal expenditures. Total Global AIDS expenditures totaled $41,208,584. Subaward reports were not independently reported in the FSRS. Identification as a repeat finding, if applicable: 2021-002 Recommendation: We recommend that VUMC implement internal controls and a review process to ensure that subrecipients are appropriately entered into FSRS. Views of responsible officials: VUMC is a prime recipient of funding from the Centers for Disease Control and Prevention related to the Global AIDS grant and made first tier subawards of greater than $30,000. VUMC reported the subaward from VUMC, the prime, to Friends in Global Health, the subrecipient, as a single report in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) instead of filing a separate report for each subaward. Procedures and internal controls were in place for first tier subawards. VUMC has changed procedures and internal controls to report each Global AIDS subaward separately in FSRS. All subawards have been reported in FY23 in compliance with the Transparency Act.