Finding 1214258 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-05-08
Audit: 400980
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: The Foundation exceeded the salary cap set by federal grant policies, leading to unallowable costs of approximately $1,500.
  • Impacted Requirements: Compliance with U.S. Department of Health and Human Services grant policies, specifically regarding salary payments under the grant.
  • Recommended Follow-Up: Enhance internal control procedures to ensure adherence to salary cap requirements in future payroll allocations.

Finding Text

Finding No. 2025-001: Allowable Costs – Significant Deficiency – Internal Control and Compliance Finding ALN 93.068 – Chronic Diseases: Research, Control, and Prevention, Grant Number 5NU58DP006907-04-00, Grant Period: September 30, 2020 to September 29, 2025 Criteria The terms and conditions of the Foundation’s grant agreement requires that the Foundation comply with the U.S. Department of Health and Human Services grant policies. Division H, Title II, Section 202 of the CDC restricts the use of appropriated funds for salary payments to individuals under grants or extramural mechanisms. This provision limits the portion of an individual's salary that can be paid with federal funds, specifically prohibiting rates in excess of Executive Level II. Condition The Foundation did not have adequate internal control procedures in place to ensure that the salary cap is properly applied when charging the time of certain individuals who exceed the salary threshold. Context Four out of 40 payroll transactions selected for testing had used salary rates that exceeded the salary cap resulting in approximately $1,500 of unallowable costs charged to the grant. Management then reviewed and recalculated all the salary charges to the federal grant by employees whose salaries exceeded the salary cap. This resulted in reduction in salaries and benefits and indirect costs charged to the federal grant by approximately $19,000. Cause Management was aware that there was a salary cap, however, did not properly apply the salary cap to the salary base when allocating the salary to the grant. Effect Management did not fully adhere to the requirements of the grant agreement. Questioned Costs The federal expenditures were initially overstated by approximately $19,000. Management corrected the federal expenditures charged to the federal grant as part of the audit process and reduced the receivables from the Federal government. This was also adjusted in the drawdown related to February 2026 expenses. Repeat Finding No. Recommendation We recommend that management enhance current internal control procedures to ensure that the Foundation is in compliance with the grant’s terms and conditions related to the salary cap that limits the portion of an individual's salary that can be paid with federal funds. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.

Corrective Action Plan

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2025 Finding No. 2025-001: Allowable Costs – Significant Deficiency – Internal Control and Compliance Finding ALN 93.068 – Chronic Diseases: Research, Control, and Prevention, Grant Number 5NU58DP006907-04-00, Grant Period: September 30, 2020 to September 29, 2025 Corrective Action Plan 1. Planned Corrective Actions Management has implemented and will formalize the following procedures to ensure compliance with federal salary limitation requirements: A. Formal Salary Cap Calculation Control • Establish a documented procedure requiring calculation of the Executive Level II salary cap annually and whenever updated by HHS. • Maintain written documentation of the capped rate calculation for each employee whose compensation exceeds the threshold. B. Payroll Allocation Review Control • Require a secondary review by the Controller (or designated finance personnel independent of the preparer) of all payroll allocations charged to federal awards for employees subject to the salary cap. • Review will confirm that capped salary, related fringe benefits, and indirect costs are properly calculated prior to posting to the general ledger. C. Grant Compliance Checklist • Implement a standardized federal grant compliance checklist to be completed monthly prior to drawdowns. This checklist will include verification of salary cap compliance. D. Staff Training • Provide targeted training to finance and payroll staff regarding: o Executive Level II compensation limits o 2 CFR §200.430 (Compensation—personal services) o Federal cost allowability requirements 2. Implementation Timeline All corrective procedures were implemented as of February 2026, with formal documentation completed no later than March 31, 2026. Sincerely, Cynthia R. Meekins, MBA Chief Financial Officer Direct: 202.349.1141

Categories

Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
93.068 CHRONIC DISEASES: RESEARCH, CONTROL, AND PREVENTION $1.91M
93.137 COMMUNITY PROGRAMS TO IMPROVE MINORITY HEALTH $488,152