Finding 1239546 (2025-003)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414268
Organization: Upmc (PA)
Auditor: ERNST & YOUNG

AI Summary

  • Core Issue: UPMC's SEFA did not include allowable program income expenditures for Ryan White programs, leading to an understatement of federal expenditures.
  • Impacted Requirements: Compliance with Section 200.303 of Title 2 U.S. Code, which mandates effective internal controls over federal awards.
  • Recommended Follow-Up: UPMC should enhance internal controls to ensure all relevant expenditures, including program income, are accurately reported in the SEFA.

Finding Text

Internal Controls over Reporting Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services Federal Cluster: None Assistance Listing Nos.: - 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) - 93.153, Coordinated Services and Access to Research for Women, Infants, Children, and Youth (Ryan White, Part D) Federal Award Numbers: - Ryan White, Part C: H76HA31655, H76HA25775, and H76HA00617 - Ryan White, Part D: H12HA26266 Federal Award Periods: - Ryan White, Part C: April 1, 2022 through March 31, 2025; May 1, 2022 through April 30, 2026; and May 1, 2022 through April 30, 2026 - Ryan White, Part D: August 1, 2024 through July 31, 2026 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, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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: Ryan White, Part C and Part D require the use of program income under the additive method, which requires program income earned from a federally funded program is added to the federal award amount and used to further program objectives. Under the method, allowable expenditures of program income are included on the SEFA. UPMC’s SEFA did not include expenditures related to program income, which were allowable. Cause: UPMC’s SEFA included grant funds expended under the Ryan White, Part C and Part D programs but did not include program income funds expended under the Ryan White, Part C and Part D programs for the year ended December 31, 2025. Effect or potential effect: The expenditures in the SEFA for the Ryan White, Part C and Part D programs for the year ended December 31, 2025, were understated which resulted in the improper identification of major federal programs. Questioned costs: None Context: Expenditures for the Ryan White, Part C and Ryan White, Part D were understated by $7,634,679 and $1,695,912, respectively (as compared to corrected expenditures for Ryan White, Part C and Ryan White, Part D of $8,771,633and $2,181,731, respectively), which resulted in Ryan White, Part C and Ryan White, Part D being identified as major federal programs upon inclusion of the allowable expenditures from program income. Identification as a repeat finding, if applicable: Yes, this is a repeat of 2024-004 of the prior year. Recommendation: UPMC should evaluate its internal controls over the SEFA process to ensure that reported federal expenditures include both grant expenditures and applicable program income expenditures, when required, to support the accurate reporting of federal expenditures. Views of responsible officials: Management concurs with this finding. Management has remediated the control deficiency as of December 31, 2025, and has appropriately revised its processes and internal controls to expenditures of program income in the SEFA for impacted programs.

Corrective Action Plan

Federal Agency: U.S. Department of Health and Human Services Assistance Listing Nos.: 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) and 93.153, Coordinated Services and Access to Research for Women, Infants, Children, and Youth (Ryan White, Part D) Condition: Ryan White, Part C and Part D require the use of program income under the additive method, which requires program income earned from a federally funded program is added to the federal award amount and used to further program objectives. Under the method, allowable expenditures of program income are included on the SEFA. UPMC’s SEFA did not include expenditures related to program income, which were allowable. UPMC’s preliminary SEFA did not include these expenditures, which resulted in the incorrect identification of major programs. The SEFA was subsequently corrected. Corrective action plan: UPMC has remediated the control deficiency as of the period ending December 31, 2025, and has appropriately revised its processes and internal controls to expenditures of program income in the SEFA for impacted programs. Completion: September 2026

Categories

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Program Income

Other Findings in this Audit

  • 1239535 2025-001
    Material Weakness Repeat
  • 1239536 2025-002
    Material Weakness Repeat
  • 1239537 2025-003
    Material Weakness Repeat
  • 1239538 2025-003
    Material Weakness Repeat
  • 1239539 2025-003
    Material Weakness Repeat
  • 1239540 2025-003
    Material Weakness Repeat
  • 1239541 2025-003
    Material Weakness Repeat
  • 1239542 2025-003
    Material Weakness Repeat
  • 1239543 2025-003
    Material Weakness Repeat
  • 1239544 2025-003
    Material Weakness Repeat
  • 1239545 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $5.92M
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $1.70M
14.267 CONTINUUM OF CARE PROGRAM $1.03M
93.600 HEAD START $375,223
93.965 COAL MINERS RESPIRATORY IMPAIRMENT TREATMENT CLINICS AND SERVICES $351,354
93.253 POISON CENTER SUPPORT AND ENHANCEMENT GRANT $341,978
84.215J FULL SERVICE COMMUNITY SCHOOLS PROGRAM $341,441
93.211 TELEHEALTH PROGRAMS $341,080
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $331,960
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $310,838
93.788 OPIOID STR $291,489
93.493 CONGRESSIONAL DIRECTIVES $250,000
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $237,977
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $231,029
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $200,000
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $189,084
17.258 WIOA ADULT PROGRAM $175,500
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $170,612
93.658 FOSTER CARE TITLE IV-E $166,144
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $139,143
84.268 FEDERAL DIRECT STUDENT LOANS $126,958
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $124,471
93.928 SPECIAL PROJECTS OF NATIONAL SIGNIFICANCE $104,459
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $95,964
84.063 FEDERAL PELL GRANT PROGRAM $85,748
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $77,218
93.991 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT $65,230
16.575 CRIME VICTIM ASSISTANCE $57,420
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $51,126
93.837 CARDIOVASCULAR DISEASES RESEARCH $47,959
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $45,000
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $39,863
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $35,042
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $34,479
93.217 FAMILY PLANNING SERVICES $33,244
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $24,417
64.028 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $23,728
93.304 RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH $21,655
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $18,568
93.297 TEENAGE PREGNANCY PREVENTION PROGRAM $13,840
93.667 SOCIAL SERVICES BLOCK GRANT $12,608
93.301 SMALL RURAL HOSPITAL IMPROVEMENT GRANT PROGRAM $11,507
64.125 VOCATIONAL AND EDUCATIONAL COUNSELING FOR SERVICEMEMBERS AND VETERANS $11,255
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $6,500
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $6,500
93.599 CHAFEE EDUCATION AND TRAINING VOUCHERS PROGRAM (ETV) $5,000
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $2,750
94.006 AMERICORPS STATE AND NATIONAL 94.006 $1,452
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1,000
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $-330
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $-4,236