Finding Text
Finding 2025-005: Reporting (Significant Deficiency) Federal Agency: National Institute of Health Federal Program: All of Us Research Program Assistance Listing Number: 93.368 Criteria: As noted in 2 CFR §200.303 "The non-Federal entity must 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 or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: We noted one instance in which there was no documented approval date of a report, and one instance in which the submission of a report was not timely in accordance with the award agreement. Cause: The Foundation does not have the appropriate internal controls in place to ensure that all internal reviews over reports are documented with a date of review. In addition, the Foundation is lacking internal controls to ensure that all reports are submitted timely in line with award agreement requirements. Effect or Potential Effect: Without proper dating of internal review and approval over reports, there exists the possibility that the review was not done prior to submission and information reported is inaccurate. Untimely submission of reports could result in withholding of funding. Questioned Costs: None noted as this compliance requirement is an administrative reporting requirement that does not impact cost eligibility. Context: Our audit procedures consisted of testwork performed over a sample of reports required to be submitted during the year under audit. We consider our sample to be representative of the population. The issue appears to be systematic in nature. Identification as a Repeat Finding: Refer to finding 2024-005. Recommendation: We recommend that the Foundation ensure that all approvals over performance and financial reporting are documented along with the date of review. In addition, we recommend the Foundation implement procedures to ensure that all reports are submitted within the specific timeframes specified in award agreements.