Finding 1225490 (2025-003)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-07-31
Audit: 408355
Organization: Meharry Medical College (TN)
Auditor: CROSSLIN PLLC

AI Summary

  • Core Issue: The College failed to provide documentation for required subrecipient monitoring, impacting compliance with federal regulations.
  • Impacted Requirements: Noncompliance with 2 CFR §200.332 due to inadequate oversight and documentation retention.
  • Recommended Follow-Up: Strengthen monitoring controls by formalizing procedures, centralizing records, and assigning clear oversight responsibilities.

Finding Text

Federal Program: Research and Development Cluster Criteria The College, as a pass-through entity, is required to monitor the activities of subrecipients as necessary to ensure subawards are used for authorized purposes and in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. Such monitoring includes reviewing financial and programmatic reports, following up on identified deficiencies, ensuring timely corrective action, and maintaining adequate documentation evidencing the performance of monitoring and oversight procedures. Condition During testing of subrecipient monitoring procedures for the Research and Development Cluster, the College was unable to provide documentation evidencing that required subrecipient monitoring confirmations and related monitoring procedures were performed for one of their subrecipients during the period July 1, 2024 through June 30, 2025. Management indicated that due to staffing turnover within the Grants & Contracts Office, the College could not verify whether monitoring confirmations were requested or received during the audit period. In addition, supporting documentation evidencing the performance of monitoring activities was not maintained or available for audit review. Cause The College experienced staffing turnover within the Grants & Contracts Office which resulted in a breakdown in controls over subrecipient monitoring documentation retention and oversight procedures. Effect The College was unable to demonstrate compliance with subrecipient monitoring requirements in accordance with 2 CFR §200.332. As a result, there is an increased risk that noncompliance by subrecipients may not be identified, monitored, or addressed in a timely manner. Questioned Costs None. Recommendation We recommend the College strengthen controls over subrecipient monitoring by: implementing formalized monitoring procedures and documentation retention requirements, maintaining centralized records of monitoring activities and confirmations, assigning clear responsibility for monitoring oversight, and implementing supervisory review controls to ensure compliance with Uniform Guidance requirements. Views of Responsible Officials See Management Corrective Action Plan. The College had no prior year findings reported.

Corrective Action Plan

Action Taken/Planned: Management acknowledges the deficiencies identified in subrecipient monitoring controls during FY25. These deficiencies occurred during a period of substantial growth in the College's sponsored programs portfolio, organizational restructuring, staffing constraints, and continued refinement of grants administration processes. In response, the College implemented a comprehensive transformation of its grants management framework during FY26. Corrective actions include establishment of the Unified Grants Hub, creation of a dedicated Subaward Manager position, addition of specialized post-award personnel, establishment of a Grants Management Task Force, implementation of formalized subrecipient monitoring procedures and documentation requirements, expansion of grants management training, enhanced coordination among Finance, Research Administration, Compliance, Budget, and Treasury functions, and deployment of Power BI reporting tools to strengthen oversight and compliance monitoring. Anticipated Completion Date/Date Completed: The majority of corrective actions were implemented during FY2026. The Unified Grants Hub, staffing enhancements, Grants Management Task Force, and enhanced monitoring procedures were operational as of June 30, 2026. Ongoing monitoring and compliance reviews will continue thereafter.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1225400 2025-003
    Material Weakness Repeat
  • 1225401 2025-003
    Material Weakness Repeat
  • 1225402 2025-003
    Material Weakness Repeat
  • 1225403 2025-003
    Material Weakness Repeat
  • 1225404 2025-003
    Material Weakness Repeat
  • 1225405 2025-003
    Material Weakness Repeat
  • 1225406 2025-003
    Material Weakness Repeat
  • 1225407 2025-003
    Material Weakness Repeat
  • 1225408 2025-003
    Material Weakness Repeat
  • 1225409 2025-003
    Material Weakness Repeat
  • 1225410 2025-003
    Material Weakness Repeat
  • 1225411 2025-003
    Material Weakness Repeat
  • 1225412 2025-003
    Material Weakness Repeat
  • 1225413 2025-003
    Material Weakness Repeat
  • 1225414 2025-003
    Material Weakness Repeat
  • 1225415 2025-003
    Material Weakness Repeat
  • 1225416 2025-003
    Material Weakness Repeat
  • 1225417 2025-003
    Material Weakness Repeat
  • 1225418 2025-003
    Material Weakness Repeat
  • 1225419 2025-003
    Material Weakness Repeat
  • 1225420 2025-003
    Material Weakness Repeat
  • 1225421 2025-003
    Material Weakness Repeat
  • 1225422 2025-003
    Material Weakness Repeat
  • 1225423 2025-003
    Material Weakness Repeat
  • 1225424 2025-003
    Material Weakness Repeat
  • 1225425 2025-003
    Material Weakness Repeat
  • 1225426 2025-003
    Material Weakness Repeat
  • 1225427 2025-003
    Material Weakness Repeat
  • 1225428 2025-003
    Material Weakness Repeat
  • 1225429 2025-003
    Material Weakness Repeat
  • 1225430 2025-003
    Material Weakness Repeat
  • 1225431 2025-003
    Material Weakness Repeat
  • 1225432 2025-003
    Material Weakness Repeat
  • 1225433 2025-003
    Material Weakness Repeat
  • 1225434 2025-003
    Material Weakness Repeat
  • 1225435 2025-003
    Material Weakness Repeat
  • 1225436 2025-003
    Material Weakness Repeat
  • 1225437 2025-003
    Material Weakness Repeat
  • 1225438 2025-003
    Material Weakness Repeat
  • 1225439 2025-003
    Material Weakness Repeat
  • 1225440 2025-003
    Material Weakness Repeat
  • 1225441 2025-003
    Material Weakness Repeat
  • 1225442 2025-003
    Material Weakness Repeat
  • 1225443 2025-003
    Material Weakness Repeat
  • 1225444 2025-003
    Material Weakness Repeat
  • 1225445 2025-003
    Material Weakness Repeat
  • 1225446 2025-003
    Material Weakness Repeat
  • 1225447 2025-003
    Material Weakness Repeat
  • 1225448 2025-003
    Material Weakness Repeat
  • 1225449 2025-003
    Material Weakness Repeat
  • 1225450 2025-003
    Material Weakness Repeat
  • 1225451 2025-003
    Material Weakness Repeat
  • 1225452 2025-003
    Material Weakness Repeat
  • 1225453 2025-003
    Material Weakness Repeat
  • 1225454 2025-003
    Material Weakness Repeat
  • 1225455 2025-003
    Material Weakness Repeat
  • 1225456 2025-003
    Material Weakness Repeat
  • 1225457 2025-003
    Material Weakness Repeat
  • 1225458 2025-003
    Material Weakness Repeat
  • 1225459 2025-003
    Material Weakness Repeat
  • 1225460 2025-003
    Material Weakness Repeat
  • 1225461 2025-003
    Material Weakness Repeat
  • 1225462 2025-003
    Material Weakness Repeat
  • 1225463 2025-003
    Material Weakness Repeat
  • 1225464 2025-003
    Material Weakness Repeat
  • 1225465 2025-003
    Material Weakness Repeat
  • 1225466 2025-003
    Material Weakness Repeat
  • 1225467 2025-003
    Material Weakness Repeat
  • 1225468 2025-003
    Material Weakness Repeat
  • 1225469 2025-003
    Material Weakness Repeat
  • 1225470 2025-003
    Material Weakness Repeat
  • 1225471 2025-003
    Material Weakness Repeat
  • 1225472 2025-003
    Material Weakness Repeat
  • 1225473 2025-003
    Material Weakness Repeat
  • 1225474 2025-003
    Material Weakness Repeat
  • 1225475 2025-003
    Material Weakness Repeat
  • 1225476 2025-003
    Material Weakness Repeat
  • 1225477 2025-003
    Material Weakness Repeat
  • 1225478 2025-003
    Material Weakness Repeat
  • 1225479 2025-003
    Material Weakness Repeat
  • 1225480 2025-003
    Material Weakness Repeat
  • 1225481 2025-003
    Material Weakness Repeat
  • 1225482 2025-003
    Material Weakness Repeat
  • 1225483 2025-003
    Material Weakness Repeat
  • 1225484 2025-003
    Material Weakness Repeat
  • 1225485 2025-003
    Material Weakness Repeat
  • 1225486 2025-003
    Material Weakness Repeat
  • 1225487 2025-003
    Material Weakness Repeat
  • 1225488 2025-003
    Material Weakness Repeat
  • 1225489 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $87.85M
93.375 Endowment Grant for Health Disparities $10.00M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $6.57M
93.157 CENTERS OF EXCELLENCE $5.95M
93.266 HEALTH SYSTEMS STRENGTHENING AND HIV/AIDS PREVENTION, CARE AND TREATMENT UNDER THE PRESIDENT'S EMERGENCY PLAN FOR AIDS RELIEF $2.71M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $951,468
93.493 CONGRESSIONAL DIRECTIVES $919,830
93.397 CANCER CENTERS SUPPORT GRANTS $715,017
93.822 HEALTH CAREERS OPPORTUNITY PROGRAM (HCOP) $501,530
84.033 FEDERAL WORK-STUDY PROGRAM $459,010
93.788 OPIOID STR $452,366
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $436,576
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $421,537
93.917 HIV CARE FORMULA GRANTS $400,953
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $393,755
93.172 HUMAN GENOME RESEARCH $385,293
93.941 HIV DEMONSTRATION, RESEARCH, PUBLIC AND PROFESSIONAL EDUCATION PROJECTS $350,178
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $312,505
81.117 ENERGY EFFICIENCY AND RENEWABLE ENERGY INFORMATION DISSEMINATION, OUTREACH, TRAINING AND TECHNICAL ANALYSIS/ASSISTANCE $281,236
93.516 PUBLIC HEALTH TRAINING CENTERS PROGRAM $280,492
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $265,827
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $265,341
47.084 TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $207,945
93.837 CARDIOVASCULAR DISEASES RESEARCH $202,539
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $189,431
81.137 MINORITY ECONOMIC IMPACT $179,798
93.353 21ST CENTURY CURES ACT - BEAU BIDEN CANCER MOONSHOT $172,683
93.884 PRIMARY CARE TRAINING AND ENHANCEMENT $158,464
93.350 NATIONAL CENTER FOR ADVANCING TRANSLATIONAL SCIENCES $156,650
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $141,435
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $135,327
93.867 VISION RESEARCH $129,360
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $116,964
93.242 MENTAL HEALTH RESEARCH GRANTS $115,429
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $108,650
93.262 OCCUPATIONAL SAFETY AND HEALTH PROGRAM $100,721
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $88,287
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $86,639
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $83,835
93.107 AREA HEALTH EDUCATION CENTERS $77,208
93.488 NATIONAL HARM REDUCTION TECHNICAL ASSISTANCE AND SYRINGE SERVICES PROGRAM (SSP) MONITORING AND EVALUATION FUNDING OPPORTUNITY $59,027
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $49,304
16.830 REDUCING RECIDIVISM FOR FEMALE JUVENILE DELINQUENTS $45,432
93.879 MEDICAL LIBRARY ASSISTANCE $44,776
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $44,209
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $41,782
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $36,943
93.310 TRANS-NIH RESEARCH SUPPORT $31,755
93.969 PPHF GERIATRIC EDUCATION CENTERS $30,882
93.426 THE NATIONAL CARDIOVASCULAR HEALTH PROGRAM $27,540
93.352 CONSTRUCTION SUPPORT $25,343
47.083 INTEGRATIVE ACTIVITIES $16,276
93.121 ORAL DISEASES AND DISORDERS RESEARCH $16,242
10.216 1890 INSTITUTION CAPACITY BUILDING GRANTS $16,143
93.226 RESEARCH ON HEALTHCARE COSTS, QUALITY AND OUTCOMES $14,940
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $7,560
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $6,089
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $5,508
12.902 INFORMATION SECURITY GRANTS $5,288
81.U01 Sustainable Solutions for Treating PFAS Containing $4,913
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $4,802
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $4,487
93.838 LUNG DISEASES RESEARCH $3,256
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $800
66.509 SCIENCE TO ACHIEVE RESULTS (STAR) RESEARCH PROGRAM $770
93.145 HIV-RELATED TRAINING AND TECHNICAL ASSISTANCE $279
93.393 CANCER CAUSE AND PREVENTION RESEARCH $217