Finding 1214780 (2025-001)

Identification of the Federal Program Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Program Name: R&D Cluster Assistance Listing #: 93.859 Pass Through Entity: West Virginia University, University of North Dakota Award Identification: Sanford 21-673 Award Year(s): February 24, 2024–May 23, 2026 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR 200.303 requires that the non-Federal entity must “(a) establish, document and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our audit, we noted that for three of sixteen milestone invoices selected for testing, Sanford did not have documented evidence of review and approval of the study activities submitted to the pass-through entity. Cause: Based on the prior year finding, Management implemented corrective actions during FY 2025; however, certain milestone invoices had already been received prior to implementation of the updated controls and therefore were not subject to the revised review and approval procedures. Effect or Potential Effect: A lack of review and approval of milestone study activities could potentially result in unallowable activities being charged to the federal program. Questioned Costs: $0 Context: The three invoices that lacked evidence of review and approval of the study activities were received during the first two months of 2025, prior to implementation of management’s corrective action plan. Total milestone payments on this grant received during these two months totaled $120,870. Total milestone grant amounts charged to the R&D Cluster were $1,141,432 in FY 2025. The total federal expenditures for the R&D Cluster for FY 2025 were $27,155,088. Identification as a Repeat Finding: This is a repeat finding of 2024-004. Recommendation: We recommend management ensure that the revised review and approval procedures that were put in place are followed. Views of Responsible Officials: As it relates to Research milestone billing for the PASC grant, procedures were revised in 2025 after the 2024 Audit. Upon receipt of invoice and payment from PASC, the Research Billing team will review and provide notification to Research Director and Research Manager via email if the invoice and payment received matches to what is shown as owed in our systems. The Corrective Action Plan from the 2024 Audit was already put into place however this is a repeat finding due to the timing of the 2024 finding.