Finding 1214670 (2024-002)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2026-05-14
Audit: 401404
Auditor: 911194016

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to allowable costs for federal awards.
  • Impacted Requirements: Compliance with U.S. CFR 200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: AAHI should strengthen internal controls to ensure proper documentation and management approval for all costs charged to federal awards.

Finding Text

Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities. Federal Agency: All awards within the Research and Development Cluster Program Title: All awards within the Research and Development Cluster Assistance Listing Number: All awards within the Research and Development Cluster Award Number: All awards within the Research and Development Cluster Award Period: All awards within the Research and Development Cluster Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Section 200.303 requires that each recipient of federal awards “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition/Context for Evaluation During our audit, we tested nonpayroll costs charged to the federal awards for adherence to necessary compliance requirements and internal control over compliance requirements. Out of 25 sample selections, we noted the following related to seven sample items: - Five of seven sample items selected involved overcharges to the grants. All five showed management approval for the incorrect amounts. - One of seven sample items selected had no supporting documentation. - One of seven sample items had no management approval. Questioned Costs $1,790 Effect or Potential Effect AAHI may have charged unallowable or incorrect costs to the federal awards. Repeat Finding No. Recommendation We recommend AAHI implement the necessary internal controls to (1) ensure documentation is retained to support costs spent on federal awards and (2) ensure all costs are properly approved and for the correct amounts. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

􀀫􀁎􀁓􀁉􀁎􀁓􀁌􀀅􀀗􀀕􀀗􀀙􀑛􀀕􀀕􀀖􀀟 Significant deficiency in internal controls over financial reporting related to the recognition of grant and contract receivables and inventory Contact Person NAME: Keeley Foley PHONE: 206.381.0883 E-Mail: keeley.foley@aahi.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned Access to Advanced Health Institute’s (AAHI’s) response to the recommendation: 1. Engage Escalon Financial Services to review/update policies and procedures for grant receivable recognition per GAAP (FASB ASC 958) and Uniform Guidance (distinguish unconditional versus conditional grants, proper cutoff/revenue recognition) 2. Implement quarterly independent review of year-end receivable balances and revenue entries by Escalon. 3. Conduct training for finance staff on GAAP grant recognition (completion tracked via signed attendance sheets) (Escalon is GAAP trained and certified) 4. Test 100% of material grant receivables at next fiscal year-end close for proper recognition (Ensure process is full proof and no deviations of process in prior fiscal year occurred) 5. In addition, AAHI will implement controls over recognition of inventory Responsible party: Escalon with Operations Director and Keeley Foley(oversight) Anticipated Completion Date May 2026 􀀫􀁎􀁓􀁉􀁎􀁓􀁌􀀅􀀗􀀕􀀗􀀙􀑛􀀕􀀕􀀗􀀟 Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities Contact Person NAME: Keeley Foley PHONE: 206.381.0883 E-Mail: keeley.foley@aahi.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned AAHI’s response to the recommendation: 1. Formalize written policies and procedures for allowable costs per 2CFR 200 Subpart E (necessary, 206.381.0883 222 5th Ave N, Seattle,WA 98109 www.aahi.org reasonable, allocable, documented). 2. Require pre-expenditure requisition approval by Principal Investigator (PI) for all grant-related expenses (tracked in project management system). 3. Mandate dual review and recertification of invoices and drawdowns: PI and Director of Operations (documented sign-off required before payment/submission) 4. Perform monthly compliance reconciliations (grant budget vs. actual expenditures) with variance resolution documented. 5. Deliver annual training, and otherwise as needed, to PIs and staff on allowable/unallowable costs (tracked via attendance and quiz scores above 80%) 6. Conduct quarterly internal monitoring of 25% sample of grant expenses for allowability and compliance. Responsible party: Keeley Foley (oversight), Director of Operations (daily enforcement), Escalon (support) Anticipated Completion Date May 2026

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1214663 2024-002
    Material Weakness Repeat
  • 1214664 2024-002
    Material Weakness Repeat
  • 1214665 2024-002
    Material Weakness Repeat
  • 1214666 2024-002
    Material Weakness Repeat
  • 1214667 2024-002
    Material Weakness Repeat
  • 1214668 2024-002
    Material Weakness Repeat
  • 1214669 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.RD Multivalent Flavivirus Vaccine Development Using a Flexible Replication RNA Platform $2.78M
93.RD Advanced Development and Clinical Evaluation of a Synthetic Intranasal Entamoeba Histolytica Vaccine Containing Adjuvant $1.34M
93.RD Development of Vaccine Candidates for Biodefenses, AMR Infections and Emerging Infectious Diseases $1.32M
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $50,523
93.RD Adjuvant Discovery Program $47,422
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $9,244