Finding Text
Finding No. 2025 - 001: Federal Agency: Department of Health and Human Services Federal Program Title: Prevention of Disease, Disability, and Death through Immunization and Control of Respiratory and Related Diseases Federal Assistance Listing Number: 93.083 Award Period: January 1, 2025 through December 31, 2025 Pass-through Entity: Council of Medical Specialty Societies ("CMSS") Federal Award Identification Number and Year: Subaward No. 101 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria In accordance with 2 CFR 200.510 (Financial Statements), an auditee must prepare a schedule of expenditures of Federal awards ("SEFA") for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 2CFR 200.502. At a minimum, the schedule must include: All individual Federal programs by Federal agency. For Federal awards received as a subrecipient, the name of the pass-through entity and identifying number assigned by the pass-through entity must be included. Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. Include the total amount provided to subrecipients from each Federal program. Condition The Organization had revisions to the SEFA and management’s review and approval process did not detect the following errors that were identified during the audit procedures performed: An incorrect de minimis indirect cost rate was used and charged to a federal award. Approximately $65,000 of federal expenditures were omitted from the initial SEFA. Subrecipient costs from the prior year were charged to the current year due to incomplete accruals in the prior year. As a result, the SEFA was not complete or accurate prior to submission for audit. Cause The Organization’s internal controls over the preparation and review of the SEFA were not operating effectively. Effect or Potential Effect Inadequate controls over the preparation of the SEFA could result in financial misstatements or potential noncompliance. Questioned Costs N/A Identification as a Repeat Finding This finding is not a repeat finding Recommendation We recommend the Organization strengthen its policies, procedures, and controls for the identification of federal awards to ensure a complete and accurate SEFA is prepared in a timely manner. Views of the Responsible Officials Management concurs with the finding and related recommendation. While the Organization completed its federal award activity in May 2025 and does not currently anticipate additional federal award activity, it recognizes the importance of compliance with grant reporting requirements, including the accurate preparation of the Schedule of Expenditures of Federal Awards. In response to this finding, the Organization has enhanced its procedures for determination of the appropriate indirect cost and strengthened its internal controls by implementing additional review and approval processes over grant expense reporting. These improvements, particularly in the review and approval functions, are designed to promote the timely and accurate reporting of grant activity, including SEFA preparation, should the Organization be subject to Single Audit requirements in the future. The Organization further has initiated repayment of indirect costs reported pursuant to the incorrect de minimis indirect cost rate, to the primary awardee.