Finding 1216416 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-06-03
Audit: 402933
Organization: Veterans Health Foundation (PA)

AI Summary

  • Core Issue: The Foundation did not consistently follow its own controls for independent review and approval of drawdown requests.
  • Impacted Requirements: This violates 2 CFR 200.303, which mandates effective internal controls over Federal awards.
  • Recommended Follow-Up: Strengthen procedures to ensure all drawdown requests are reviewed and approved before submission, with documented evidence maintained.

Finding Text

Finding 2025-001: Research and Development Cluster Cash Management Draw Approvals Federal Agency: Department of Health and Human Services Criteria: 2 CFR 200.303 requires the recipient to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance the award is managed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Foundation has established independent review and approval of drawdown requests by the CEO/Controller as key control over draw requests. Condition: The Foundation did not consistently follow its established controls requiring independent review and approval of drawdown reimbursement requests prior to submission. During our testing of drawdown request controls within the Research and Development Cluster, we noted that 4 of 66 drawdown reimbursement requests tested (the entire population of drawdown requests) were submitted without documentation of independent review and approval. Based on the requests tested, the amounts submitted were accurate supported, and no instances of noncompliance were identified. Cause: The exceptions appear to have resulted from oversight in the review process, which led to drawdown requests being submitted before approval was documented. Additionally, the exceptions occurred during a period in which the Foundation was transitioning finance personnel responsibilities. Effect: Certain drawdown requests were submitted before the Foundation’s key control was evidenced as having been performed. Repeat Finding: N/A Questioned Costs: None Recommendation: We recommend the Foundation strengthen procedures to ensure all drawdown requests are reviewed and approved by the appropriate independent party prior to submission and that evidence of such review is consistently maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See attached corrective action plan.

Corrective Action Plan

Veterans’ Health Foundation Corrective Action Plan Federal Drawdown Internal Control Finding 2025-001 Management agrees with the finding. The identified exceptions resulted from inconsistent retention of documented review evidence during a period of transition in finance personnel. While drawdown requests were supported by allowable expenditures and subject to financial oversight, documentation evidencing the control was not consistently maintained for certain transactions. To strengthen internal controls over federal drawdown requests and ensure continued compliance with 2 CFR 200.303, the Veterans Health Foundation will revise and formalize its drawdown procedures as follows: 1. Federal drawdown requests will be prepared by designated finance personnel and supported by appropriate expenditure documentation. 2. The Controller will review supporting documentation and authorize all federal drawdown requests prior to submission to ensure the accuracy, allowability, and appropriateness of reimbursement requests. 3. The CEO will perform and document a monthly reconciliation review of drawdown activity and related expenditures as an additional oversight and monitoring control. 4. The Foundation will update its formal policies and procedures within 60 days to reflect the revised drawdown preparation, review, authorization, reconciliation, and documentation retention requirements. 5. The Foundation is strengthening its document storage and records retention processes to ensure supporting documentation for drawdowns and other federal award activities is consistently maintained, centrally stored, and readily accessible for audit and compliance purposes. 6. As part of the Foundation’s broader administrative modernization initiative, the Foundation is implementing a new cloud-based file storage and records management system during the current fiscal year to improve document retention, access controls, continuity of operations, and long-term compliance oversight. 7. Management has communicated the revised control procedures to finance personnel and will monitor compliance with the updated process. The Foundation believes these corrective actions adequately address the finding and strengthen internal controls over federal cash management activities and records retention. Responsible Officials: Controller and Chief Executive Officer Anticipated Completion Date: Policy updates will be completed within 60 days. All other corrective actions have been implemented effective immediately, with the new cloud-based file storage system to be implemented during the current fiscal year.

Categories

Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1216395 2025-001
    Material Weakness Repeat
  • 1216396 2025-001
    Material Weakness Repeat
  • 1216397 2025-001
    Material Weakness Repeat
  • 1216398 2025-001
    Material Weakness Repeat
  • 1216399 2025-001
    Material Weakness Repeat
  • 1216400 2025-001
    Material Weakness Repeat
  • 1216401 2025-001
    Material Weakness Repeat
  • 1216402 2025-001
    Material Weakness Repeat
  • 1216403 2025-001
    Material Weakness Repeat
  • 1216404 2025-001
    Material Weakness Repeat
  • 1216405 2025-001
    Material Weakness Repeat
  • 1216406 2025-001
    Material Weakness Repeat
  • 1216407 2025-001
    Material Weakness Repeat
  • 1216408 2025-001
    Material Weakness Repeat
  • 1216409 2025-001
    Material Weakness Repeat
  • 1216410 2025-001
    Material Weakness Repeat
  • 1216411 2025-001
    Material Weakness Repeat
  • 1216412 2025-001
    Material Weakness Repeat
  • 1216413 2025-001
    Material Weakness Repeat
  • 1216414 2025-001
    Material Weakness Repeat
  • 1216415 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.135 CENTERS FOR RESEARCH AND DEMONSTRATION FOR HEALTH PROMOTION AND DISEASE PREVENTION $196,432
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $70,224
93.837 CARDIOVASCULAR DISEASES RESEARCH $54,526
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $50,641
93.173 RESEARCH RELATED TO DEAFNESS AND COMMUNICATION DISORDERS $43,307
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $21,950
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $11,725
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $8,109
93.350 NATIONAL CENTER FOR ADVANCING TRANSLATIONAL SCIENCES $7,214
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $1,450
93.847 DIABETES, DIGESTIVE, AND KIDNEY DISEASES EXTRAMURAL RESEARCH $276
93.866 AGING RESEARCH $-9,614