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.