Finding 1239051 (2023-003)

Material Weakness Repeat Finding
Requirement
ABCIJL
Questioned Costs
-
Year
2023
Accepted
2026-09-30
Audit: 413916
Organization: Upmc (PA)

AI Summary

  • Core Issue: UPMC lacked sufficient evidence to demonstrate effective internal controls over key compliance areas for the Ryan White Program.
  • Impacted Requirements: Compliance requirements affected include Allowability, Cash Management, Procurement, Suspension and Debarment, Program Income, and Reporting.
  • Recommended Follow-Up: UPMC should implement and document all control policies related to compliance processes to ensure evidence is maintained moving forward.

Finding Text

Ryan White Program Review and Approval Internal Controls Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Federal Cluster: None Assistance Listing No.: 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) Federal Award Numbers: H76HA31655, H76HA25775, H76HA00617, and P06HA9851 Federal Award Period: April 1, 2022 through March 31, 2025; May 1, 2022 through April 30, 2025; May 1, 2022 through April 30, 2025; and September 1, 2023 through August 31, 2024 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “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: For the period under audit, UPMC did not retain sufficient evidence to support the design and operation of internal controls over the following compliance requirements: • Allowability • Cash Management • Procurement and Suspension and Debarment • Program Income • Reporting Cause: The design and operation of UPMC’s controls over the program did not incorporate appropriate procedures to document and maintain evidence to support the operation of such controls. Revisions to the design and operation of UPMC’s controls were made subsequent to year-end, thus leading to no evidence of controls during the year under audit. Effect or Potential Effect: If appropriate controls are not documented and functioning properly, program data used to determine allowability and program income and compile required reports may not be complete and accurate resulting in noncompliance with the applicable compliance requirements or questioned costs. Questioned Costs: None Context: Total federal expenditures on the SEFA for Ryan White, Part C totaled $7,149,887 for the year ended December 31, 2023. Identification as a Repeat Finding, if Applicable: No. Recommendation: UPMC should ensure all control policies related to the applicable compliance processes are implemented and that evidence of each control is maintained. Views of Responsible Officials: Management concurs with this finding. Subsequent to December 31, 2023, management revised the internal control policies and procedures for Ryan White, Part C to appropriately maintain evidence of controls performed.

Corrective Action Plan

Federal Agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) Condition: For the period under audit, UPMC did not retain sufficient evidence to support the design and operation of internal controls over the applicable compliance requirements, including allowability; cash management; matching, level of effort and earmarking, program income, and reporting. Corrective Action Plan: UPMC has remediated this deficiency. Effective January 1, 2025, management revised the internal control policies and procedures for Ryan White, Part C to appropriately maintain evidence of controls performed. Completion: May 2025

Categories

Procurement, Suspension & Debarment Reporting

Other Findings in this Audit

  • 1239037 2023-001
    Material Weakness Repeat
  • 1239038 2023-002
    Material Weakness Repeat
  • 1239039 2023-002
    Material Weakness Repeat
  • 1239040 2023-002
    Material Weakness Repeat
  • 1239041 2023-002
    Material Weakness Repeat
  • 1239042 2023-002
    Material Weakness Repeat
  • 1239043 2023-002
    Material Weakness Repeat
  • 1239044 2023-002
    Material Weakness Repeat
  • 1239045 2023-003
    Material Weakness Repeat
  • 1239046 2023-003
    Material Weakness Repeat
  • 1239047 2023-003
    Material Weakness Repeat
  • 1239048 2023-003
    Material Weakness Repeat
  • 1239049 2023-003
    Material Weakness Repeat
  • 1239050 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 COVID-19 PROVIDER RELIEF FUND $49.20M
97.036 COVID-19 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $42.18M
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $11.61M
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $1.36M
84.268 FEDERAL DIRECT STUDENT LOANS $601,865
93.600 HEAD START $593,391
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $506,362
93.155 RURAL HEALTH RESEARCH CENTERS $405,568
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $332,540
93.253 POISON CENTER SUPPORT AND ENHANCEMENT GRANT $320,859
84.215J FULL SERVICE COMMUNITY SCHOOLS PROGRAM $304,903
10.557 SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $236,197
84.425N COVID-19 EDUCATION STABILIZATION FUND $223,035
93.965 COAL MINERS RESPIRATORY IMPAIRMENT TREATMENT CLINICS AND SERVICES $219,884
84.063 FEDERAL PELL GRANT PROGRAM $193,625
93.556 PROMOTING SAFE AND STABLE FAMILIES $192,584
93.788 OPIOID STR $175,182
17.258 WIA ADULT PROGRAM $149,500
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $135,526
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $95,827
14.267 CONTINUUM OF CARE PROGRAM $82,445
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $74,035
93.301 COVID-19 SMALL RURAL HOSPITAL IMPROVEMENT GRANT PROGRAM $70,000
93.928 SPECIAL PROJECTS OF NATIONAL SIGNIFICANCE $66,823
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $66,002
93.242 MENTAL HEALTH RESEARCH GRANTS $57,705
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES_PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $53,347
84.425F COVID-19 EDUCATION STABILIZATION FUND $52,991
16.758 IMPROVING THE INVESTIGATION AND PROSECUTION OF CHILD ABUSE AND THE REGIONAL AND LOCAL CHILDREN'S ADVOCACY CENTERS $45,577
64.125 VOCATIONAL AND EDUCATIONAL COUNSELING FOR SERVICEMEMBERS AND VETERANS $40,619
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $37,227
93.493 CONGRESSIONAL DIRECTIVES $36,173
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $34,500
23.002 APPALACHIAN AREA DEVELOPMENT $30,804
93.847 DIABETES, DIGESTIVE, AND KIDNEY DISEASES EXTRAMURAL RESEARCH $26,179
16.575 CRIME VICTIM ASSISTANCE $25,728
93.217 FAMILY PLANNING_SERVICES $24,767
84.126 REHABILITATION SERVICES_VOCATIONAL REHABILITATION GRANTS TO STATES $23,846
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $23,283
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $22,679
93.837 CARDIOVASCULAR DISEASES RESEARCH $16,500
93.870 COVID-19 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $11,945
64.028 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $11,244
93.958 COVID-19 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $11,228
93.301 SMALL RURAL HOSPITAL IMPROVEMENT GRANT PROGRAM $11,112
93.912 RURAL HEALTH CARE SERVICES OUTREACH, RURAL HEALTH NETWORK DEVELOPMENT AND SMALL HEALTH CARE PROVIDER QUALITY IMPROVEMENT $8,302
93.667 SOCIAL SERVICES BLOCK GRANT $7,890
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $6,933
17.278 WIA DISLOCATED WORKER FORMULA GRANTS $6,500
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $6,500
17.245 TRADE ADJUSTMENT ASSISTANCE $5,000
93.599 CHAFEE EDUCATION AND TRAINING VOUCHERS PROGRAM (ETV) $5,000
10.572 WIC FARMERS' MARKET NUTRITION PROGRAM (FMNP) $4,623
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $3,750
93.866 AGING RESEARCH $3,375
93.083 PREVENTION OF DISEASE, DISABILITY, AND DEATH THROUGH IMMUNIZATION AND CONTROL OF RESPIRATORY AND RELATED DISEASES $3,258
93.658 FOSTER CARE_TITLE IV-E $2,894
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $2,872
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $923
93.600 COVID-19 HEAD START $76