Finding 1236573 (2025-003)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2025
Accepted
2026-09-25

AI Summary

  • Core Issue: The organization lacks formal written policies for key compliance areas under Uniform Guidance, increasing the risk of noncompliance.
  • Impacted Requirements: Compliance with Title 2 CFR Part 200 requires documented policies on financial management, procurement, conflict of interest, and travel.
  • Recommended Follow-Up: Management should create, approve, and regularly update written policies to ensure adherence to all Uniform Guidance requirements.

Finding Text

MATERIAL WEAKNESS DUE TO LACK OF DOCUMENTED WRITTEN POLICIES RELATED TO UNIFORM GUIDANCE REQUIREMENTS Federal Agency: Uniformed Services University of the Health Sciences Pass-Through Agency: The Henry M. Jackson Foundation for the Advancement of Military Medicine Program Name: Uniformed Services University Medical Research Projects Assistance Listing Number: 12.750 Award Numbers: 67656, 67659, 67966 Category of Finding: Internal control over compliance Criteria: Title 2 CFR Part 200 (Uniform Guidance) requires non-Federal entities receiving Federal awards to establish and maintain effective internal controls and comply with applicable Federal requirements. Written policies and procedures should address key compliance areas, including financial management, procurement, conflict of interest, travel, and other applicable Uniform Guidance requirements. Condition: The Organization does not maintain formal written policies governing several key compliance areas required under Uniform Guidance, including financial management, procurement, conflict of interest, and travel costs. Context: The condition was identified during our evaluation of the Organization's compliance with Uniform Guidance requirements applicable to its Federal awards. Cause: Management has relied on established practices and institutional knowledge rather than formally documented policies and procedures governing Federal award compliance. Effect: The absence of documented policies increases the risk of inconsistent application of Uniform Guidance requirements and may result in noncompliance with Federal regulations. Repeat Finding: This is a new finding. Recommendation: We recommend management develop, approve, and implement written policies and procedures addressing all significant Uniform Guidance compliance requirements applicable to the Organization's Federal awards. Policies should be reviewed periodically and updated as regulations or organizational practices change. Views of Responsible Officials and Corrective Action Plan: See corrective action plan in the financial statements.

Corrective Action Plan

Condition: The Organization does not maintain formal written policies governing several key compliance areas required under Uniform Guidance, including financial management, procurement, conflict of interest, and travel costs. Management Response: Management concurs with the finding. The Organization recognizes that it has historically relied on established practices and institutional knowledge rather than formally documented policies and procedures governing Federal award compliance. Management acknowledges that written policies are necessary to establish consistent expectations, clearly assign responsibilities, and strengthen internal controls over compliance with Uniform Guidance requirements. Planned Corrective Action: To address this finding, management will develop, approve, and implement formal written policies and procedures addressing significant Uniform Guidance compliance requirements applicable to the Organization’s Federal awards. The process will require: 1. The Organization to develop written policies and procedures addressing applicable Federal award compliance requirements, including financial management, procurement, conflict of interest, travel costs, and other significant areas applicable to the Organization’s Federal awards. 2. The policies and procedures to establish clear requirements for approvals, supporting documentation, record retention, responsible personnel, and compliance monitoring. 3. Management to review the policies and procedures to ensure they are consistent with applicable Uniform Guidance requirements, Federal award terms and conditions, and the Organization’s current practices. 4. The policies and procedures to be formally approved by management and communicated to employees and other individuals responsible for administering or expending Federal award funds. 5. Appropriate training or guidance to be provided to personnel responsible for Federal award activities to promote consistent application of the policies and procedures. 6. Management to periodically review the policies and procedures and update them, as necessary, when Federal regulations, Uniform Guidance requirements, Federal award terms and conditions, or organizational practices change. The Organization will also assess staffing responsibilities to ensure that appropriate responsibility for implementing, maintaining, and monitoring compliance with the written policies is assigned despite limited personnel. Responsible Party: Robert L. Grossman, Managing Director Anticipated Completion Date: August 28, 2026

Categories

Procurement, Suspension & Debarment Material Weakness

Other Findings in this Audit

  • 1236570 2025-003
    Material Weakness Repeat
  • 1236571 2025-003
    Material Weakness Repeat
  • 1236572 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
12.750 UNIFORMED SERVICES UNIVERSITY MEDICAL RESEARCH PROJECTS $225,225