FAC Explorer

Finding 35898 (2022-003)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-09-29
Audit: 37993
Organization: Atrium Health, Inc. (NC)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Three individuals were charged salaries exceeding the NIH salary cap by $3,206, indicating ineffective controls over salary management.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and Uniform Guidance regarding cost allowability and salary cap limitations was not maintained.
  • Recommended Follow-Up: Management should enhance training and review policies to ensure adherence to salary cap regulations and improve internal controls.

Finding Text

Finding No. 2022-003: Allowability of Costs Federal Program: Research and Development Cluster, ALN 93.396, 93.361, 93.395, Award Numbers R01CA172513, R01NR018434, R01CA215651 Federal Agency: U.S. Department of Health and Human Services Pass through entity: N/A Federal Award year: August 6, 2020 through February 28, 2023, July 23, 2019 through July 31, 2023, August 28, 2020 through July 31, 2023 Criteria or Requirement: Per 2 CFR 200.303, the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Uniform Guidance Part ?200.300(b), statutory and national policy requirements, establishes that the non Federal entity is responsible for complying with all requirements of the Federal award. Federal awards under the Consolidated Appropriations Act 2016 (H.R. 2029) granted by HHS National Institute of Health (NIH), have restrictions on the amount of direct salary charged to the awards limited to the Executive Level II of the Federal Executive pay scale (salary cap). Uniform Guidance Part ?200.408, limitation on allowance of costs, states that the Federal award may be subject to statutory requirements that limit the allowability of costs. When the maximum allowable under a limitation is less than the total amount of the award, the amount not recoverable under the Federal award may not be charged to the Federal award. Condition Found, Including Perspective: During our testwork over the NIH salary cap, we identified three individuals in a sample of 10 with a salary charged to an award in excess of the salary cap by $3,206. The sampled salary for NIH salary cap population was a charge to the grant of $187,586. Total salary charged to NIH was $2,128,430. Cause and Possible Effect: While there is a control in place to review all effort charged to NIH grants to ensure that charges, including any relevant cost transfers, do not exceed the defined salary cap, the control was not operating effectively in order to identify the overages. Questioned Costs: $3,206 Statistical Validity: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year: No Recommendation: We recommend that management review its current policies and reinforce through training the elements necessary to fully comply with its policies and all requirements governing salary cap allowability. Views of Responsible Officials: Atrium Health management agrees with the finding. To address the current year finding, Office of Sponsored Programs has implemented internal control improvements to ensure all requirements that limit the salary cap allowability of costs are completed and documented appropriately.

Categories

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 35896 2022-004
    Significant Deficiency
  • 35897 2022-003
    Significant Deficiency
  • 35899 2022-003
    Significant Deficiency
  • 35900 2022-001
    Significant Deficiency Repeat
  • 35901 2022-002
    Significant Deficiency
  • 612338 2022-004
    Significant Deficiency
  • 612339 2022-003
    Significant Deficiency
  • 612340 2022-003
    Significant Deficiency
  • 612341 2022-003
    Significant Deficiency
  • 612342 2022-001
    Significant Deficiency Repeat
  • 612343 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 Provider Relief Fund $44.16M
21.027 Coronavirus State and Local Fiscal Recovery Fund $2.25M
84.268 Federal Direct Student Loans $1.57M
93.361 Nursing Research $1.07M
93.889 Hospital Preparedness Program Cooperative Agreement $951,564
93.253 Poison Center Support and Enhancement Grants $848,474
93.889 Metrolina Healthcare Preparedness Region 21-22 $759,157
93.121 Orarad Renewal $749,942
93.958 Implementing A Coordinated Specialty Care (csc) Model Program in Mecklenburg County Block Grants for Community Mental Health Services $734,903
93.461 Covid-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured $651,210
93.840 Primary Care Implementation and Evaluation of Coach McLungs An Asthma Shared Decision-Making Intervention, Across A Large Healthcare System $439,180
84.GSA_MIGRATION Covid-19 Heerf Education Emergency Relief Fund (heerf) Student Aid Portion $420,200
93.391 Community Health Workers Model 2021-2023 $374,068
93.121 Oral Diseases and Disorders Research $348,327
93.323 Birth Defects and Developmental Disabilities Prevention and Surveillance $314,352
12.420 Evaluation of A New Strategy for Protocolized Antibiotic Care for Severe Open Fractures $312,509
84.063 Federal Pell Grant Program $284,444
16.320 Services for Trafficking Victims $271,355
93.889 Metrolina Healthcare Preparedness Region 22-23 $256,923
12.U00 The Mobility Toolkit: Electronically Augmented Assessment of Functional Recovery Following Lower-Extremity Trauma $221,776
93.994 Prenatal Region III Locate 2021-2022 $217,639
93.137 Minority Systemic Lupus $215,324
93.273 Alcohol Research Programs $214,458
93.136 Injury Prevention and Control Research and State and Community Based Programs $211,173
12.420 Injury Risk in Special Forces Operations $209,565
93.669 Atrium Health Cabarrus Jeff Gordan Childrens Advocacy Centers of North Carolina Department of Health and Human Services Supplemental Funds $197,625
93.365 Sickle Cell Treatment Demonstration Program $196,018
93.395 Dual Pi3k/brd4 Inhibitory Chemotype for Maximum Inhibition of Myc and Cancer $186,732
93.226 Personalized Clinical Decision Support to Improve Participation in Hospital at Home $169,407
93.394 Cancer Detection and Diagnosis Research $166,657
93.686 Recast Training $155,273
93.396 Role of Pten and Pi-3 Kinase in Medulloblastomagenesis $152,609
93.137 Speech Profiles and Cue Responsiveness After Left Hemisphere Stroke $152,272
16.575 Cabarrus Jeff Gordon Childrens Advocacy Center 2020-2022 $136,186
16.575 Stanly Butterfly House 2020-2022 $131,523
12.420 Prophylactic Nail $129,543
93.994 Perinatal/neonatal Program Region III $122,523
93.853 Preclinic Dose and Delivery Regime Optimization and Long-Term Efficacy Evaluation of Ribitol Treatment for Fkrp Related Dystroglycanopathy $119,157
93.855 Covid-19 Prevention Network (covpn) Site Preparedness Funding $112,459
93.069 Nc Public Health Preparedness 2021-2022 $102,000
93.107 Model State Supported Area Health Education Center Program (hrsa) $96,359
93.865 Natpro - Rct of Natural Vs Programmed Cycles for Frozen Embryo Transfer $88,913
93.069 Public Health Epidemiologist $79,282
93.879 Medical Library Assistance $79,048
93.323 Public Health Epidemiologist 2022-2023 $78,273
93.866 Pragmatic Evaluation of Events and Benefits of Lipid-Lowering in Older Adults (preventable) $74,140
10.310 A Nutrimetabolomics Approach to Identify the Biomarkers of Whole Grain Intake $61,828
93.145 Hiv Linkage $61,024
93.838 The Capture Study: Validating A Unique Copd Screening Tool in Primary Care $59,396
93.853 Statins Use in Intracerebral Hemorrhage Patients $55,830
93.360 A Double-Blind, Randomized, Placebo-Controlled Study to Evaluate the Efficacy and Safety of Intravenous Ganaxolone in Status Epilepticus $53,880
20.600 T- Sbirt - Traffic Counseling Toward Impaired Drivers and Seatbelt Use in A Trauma Center $52,968
93.865 Using Interactive Virtual Presence to Remotely Assist Parents with Child Restraint $52,551
93.395 Repurposing Leflunomide to Delay Progression of Smoldering Multiple Myeloma in African Americans $42,888
93.865 A Randomized Controlled Trial of Frozen Embryo Transfers Performed in Modified Natural Versus Programmed Cycles (natpro) $41,400
93.884 Training Primary Care Champions $39,318
16.575 Cabarrus Jeff Gordon Childrens Advocacy Center 2022-2024 $38,086
93.847 Aldh1l1 Polymorphisms in Regulation of Glycine Metabolism $35,929
93.884 Primary Care Training and Enhancement: Training Primary Care Champions $35,277
93.558 2021-2022 Cacnc Butterfly House $33,858
93.855 Modeling and Simulation Tools for Optimizing Design of Network-Informed Clinical Trials of Combination Hiv Prevention Interventions $32,164
16.575 Stanly Butterfly House 2022-2024 $31,908
93.360 Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $31,126
93.116 Tb Consults 2022 $30,180
93.398 Workload Intensity Nih National Clinical Trial Network (ntn) Grant Successor to Nih Cog Chair Grant $29,500
93.433 Traumatic Brain Injury Model Systems National Data and Statistical Center $27,550
93.137 Covid-19 Resources with Ahec $27,160
93.914 Ryan White Minority Aids Initiative (mai) $25,632
93.839 Blood and Marrow Transplant Clinical Trials Network $25,321
93.310 Trials and Research Network for Even More (transform-2) $25,179
93.433 Characterization and Treatment of Chronic Pain After Severe Traumatic Brain Injury $24,050
93.226 Screening and Management of Unhealthy Alcohol Use in Primary Care: Dissemination and Implementation of Pcor Evidence $23,549
93.837 Heartshare $22,345
12.420 The Major Extremity Trauma and Rehabilitation Research Consortium $22,261
93.U00 A Phase Ii, Single-Stage, Single Arm Investigation of Oral Valganciclovir Therapy in Infants with Asymptomatic Congenital Cytomegalovirus Infection $22,000
93.837 Metabolic Pathways to Cardiovascular Disease $21,913
93.395 A Randomized Phase Ii/iii Trial of De-Intensified Radiation Therapy for Patients with Early-Stage, P16-Positive, Non-Smoking Associated Oropharyngeal $21,775
93.558 2022-2023 Cacnc Butterfly House Dhhs $21,759
84.007 Federal Supplemental Education Opportunity Grant Program $21,681
20.614 Crash Injury Research and Engineering Network (ciren) Motor Vehicle Occupant Enrollment - National Highway Traffic Safety Administration Discretionary $21,482
93.958 Project Seed Expansion $21,107
93.073 Birth Defects and Developmental Disabilities Prevention and Surveillance $20,000
93.914 Covid-19 Hiv Emergency Relief Project Grants $19,780
93.395 Randomized Trial of Standard Chemotherapy Alone Or Combined with Atezolizumab As Adjuvant Therapy for Patients with Stage III Colon Cancer and Deficient Dna Mismatch Repair $19,662
93.855 Congenital and Perinatal Infections Rare Diseases $18,000
93.395 A Randomized Phase Ii/iii Open-Label Study of Ipilimumab and Nivolumab Versus Temozolomide in Patients with Newly Diagnosed Mgmt Glioblastoma (tumor O-6-Methylguanine Dna Methyltransferase) Unmethylated $17,800
93.080 Public Health Surveillance for the Prevention of Complications of Bleeding Disorders $17,628
93.395 A Randomized Phase III Study of Paclitaxel and Carboplatin with Or Without Pembrolizumab (mk-3475) for Measurable Stage III Or Iva, Stage Ivb Or Recurrent Endometrial Cancer $16,650
93.839 Sickle Cell Disease and Cardiovascular Risk Red Cell Exchange Trial (scd-Carre) $16,165
93.395 A Phase Iii, Randomized Study of Nivolumab (opdivo) Or Brentuximab Vedotin (adcetris) Plus Avd in Patients (age >/= 12 Years) with Newly Diagnosed Advanced Stage Classical Hodgkin Lympho $14,850
93.395 Childrens Oncology Group $13,750
93.914 Ryan White Part A $12,749
93.395 A Randomized Phase Ii/iii Trial of Prophylactic Cranial Irradiation with Or Without Hippocampal Avoidance for Small Cell Lung Cancer $12,200
93.839 A Comparison of Individualized Vs. Weight Based Protocols to Treat Vaso-Occlusive Episodes in Sickle Cell Disease (compare-Voe) $11,240
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $10,740
93.395 A Phase 3 Randomized Trial for Patients with De Novo Aml Comparing Standard Therapy Including Gemtuzumab Ozogamicin (go) to Cpx-351 with Go, with Flt3 Mutations and the Addition of the Flt3 Inhibitor Gilteritinib for Patients $10,200
93.395 Phase III Study of Daratumumab/rhuph20 + Lenalidomide Or Lenalidomide As Post-Autologous Stem Cell Transplant $9,384
93.856 Multimodal Treatment for Hemiplegic Shoulder Pain $8,775
93.U00 A Randomized Phase III Trial of Consolidation with Autologous Hematopoietic Cell Transplantation Followed by Maintenance $8,550
93.395 Nrg-Lu005: Limited Stage Small Cell Lung Cancer (ls-Sclc): A Phase Ii/iii Randomized Study of Chemoradiation Versus Chemoradiation Plus Atezolizumab $8,350
93.262 A Randomized, Double-Blind, Phase III Trial of Paclitaxel/trastuzumab/pertuzumab with Atezolizumab Or Placebo in First-Line Her2-Positive Metastatic Breast Cancer $7,895
93.116 Tb Consults 2021 $7,545
93.395 National Surgical Adjuvant Breast and Bowel Project (nsabp)/radiation Therapy Oncology Group (rtog)/gynecologic Oncology Group (gog) $7,000
93.395 Randomized Phase Ii/iii Trial of Adjuvant Radiation Therapy with Cisplatin, Docetaxel-Cetuximab, Or Cisplatin-Atezolizumab in Pathologic High-Risk Squamous Cell Cancer of the Head and Neck $6,550
93.433 The Traumatic Brain Injury Model Systems National Data and Statistical Center 2021-2022 $6,048
93.395 Nrg-Gu009: Parallel Phase III Randomized Trials for High-Risk Prostate Cancer Evaluating De-Intensification for Lower Genomic Risk and Intensification of Concurrent Therapy for Higher Genomic Risk with Radiation (predict-Rt) $6,000
93.853 Statins Use in Intracerebral Hemorrhage Patients (saturn) Study $5,566
12.420 Novel Topical Antibiotic Therapy to Reduce Infection After Operative Treatment of Fracturesat High Risk of Infection: Tobra -A Multicenter Randomized, Controlled Trial $5,350
93.399 National Surgical Adjuvant Breast and Bowel Project $5,225
93.395 A Phase 3 Randomized Trial of Inotuzumab Ozogamicin for Newly Diagnosed High-Risk B-All; Risk-Adapted Post-Induction Therapy for High-Risk B-All, Mixed Phenotype Acute Leukemia, and Disseminated B-Lly $5,000
93.669 Geriatrics Workforce Enhancement Program $5,000
93.360 A Randomized, Double-Blind, Multi-Center Study to Establish the Efficacy and Safety of Ceftobiprole Medocaril Compared to Daptomycin $4,950
93.394 A Phase III Clinical Trial Evaluating De-Escalation of Breast Radiation for Conservative Treatment of Stage I, Hormone Sensitive, Her2-Negative, Oncotype Recurrence Score $4,800
93.669 Butterfly House Childrens Advocacy Centers of North Carolina Department of Health and Human Services Supplemental Funds $4,705
93.395 Phase II Randomized Study of Maintenance Atezolizumab Versus Atezolizumab in Combination with Talazoparib in Patients with Slfn11 Positive Extensive Stage Small Cell Lung Cancer (es-Sclc) $4,250
21.019 Covid-19 Coronavirus Relief Fund $3,737
93.395 A Phase 3 Trial Investigating Blinatumomab in Combination with Chemotherapy in Patients with Newly Diagnosed $3,600
93.395 A Phase 3 Randomized Non-Inferiority Study of Carboplatin and Vincristine Versus Selumetinib (nsc# 748727) in Newly Diagnosed Or Previously Untreated Low-Grade Glioma (lgg) Not Associated with Brafv600e Mutations Or Systemic Neurofibromatosis Type 1 (nf1) $3,600
93.U00 Alliance for Clinical Trials in Oncology $3,500
93.110 Hemophilia Treatment Centers (sprans) $3,102
93.080 2021-2022 Nc Sickle Cell Data Collection Program $2,762
93.395 A Phase 2 Trial of Chemotherapy Followed by Response-Based Whole Ventricular & Spinal Canal Irradiation (wvsci) for Patients with Localized Non-Germinomatous Central Nervous System Germ Cell Tumor $2,700
93.395 Risk-Stratified Therapy for Am $2,700
93.395 A Randomized Phase Iii, Two-Arm Trial of Paclitaxel/carboplatin/maintenance Letrozole Versus Letrozole Monotherapy in Patients with Stage II-Iv, Primary Low-Grade Serous Carcinoma of the Ovary Or Peritoneum $2,700
93.399 International Phase 3 Trial in Philadelphia Chromosome-Positive Acute Lymphoblastic Leukemia (ph+ All) Testing Imatinib in Combination with Two Different Cytotoxic Chemotherapy Backbones $2,700
12.420 Randomized Trial of Early Hemodynamic Management of Patients Following Acute Spinal Cord Injury Temple $2,700
93.853 Sleep Smart $2,658
93.839 Clinical Transplant-Related Long-Term Outcomes of Alternative Donor Allogeneic Transplantation (ctrl-Alt-D) Bmt $2,512
93.110 Hemophilia Treatment Centers (sprans Yr5-10) $2,354
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $1,953
93.226 Short-Term Clinical Deterioration After Acute Pulmonary Embolism $1,710
93.395 A Randomized, Phase III Trial to Evaluate the Efficacy and Safety of Mk-3475 (pembrolizumab) As Adjuvant Therapy for Triple Receptor-Negative Breast Cancer with >/=1 Cm Residual Invasive Cancer Or Positive Lymph Nodes (ypn+) After Neoadjuvant Chemotherapy $1,705
12.420 Rehabilitation Enhanced by Partial Arterial Inflow Restriction $1,542
93.395 Phase III Randomized Trial of Standard Systemic Therapy (sst) Versus Standard Systemic Therapy Plus Definitive Treatment (surgery Or Radiation) of the Primary Tumor in Metastatic Prostate Cancer $1,200
93.421 Pediatric Public Health Partnership on Fetal Alcohol Spectrum Disorders $1,148
93.847 Developing A Biomarker Panel to Assess Choline Nutritional Status $1,097
93.399 Pediatric Match (molecular Analysis for Therapy Choice) $763
93.847 Apol1 Long-Term Kidney Transplantation Outcomes Network $700
93.395 A Phase 2 Study of Reduced Therapy for Newly Diagnosed Average-Risk Wnt-Driven Medulloblastoma Patients $600
93.U00 A Phase 3 Study of Active Surveillance for Low Risk and A Randomized Trial of Carboplatin Vs. Cisplatin for Standard Risk Pediatric $500
12.420 Effect of Early Weight Bearing $388
93.669 2021-2022 Cacnc Butterfly House $385
93.839 Composite Health Assessment Model for Older Adults: Applying Pre-Transplant Comorbidity, Geriatric Assessment, and Biomarkers to Predict Non-Relapse Mortality After Allogeneic Transplantation (charm) $305
93.669 2022-2023 Cacnc Butterfly House Dhhs $250
93.395 Phase Ii/iii Study of Circulating Tumor Dna As A Predictive Biomarker in Adjuvant Chemotherapy in Patients with Stage Iia Colon Cancer (cobra) $150
93.283 Virtual Network to Investigate the Trajectory of Covid-19-Related Severe Outcomes $67
93.395 Treatment of Newly Diagnosed Diffuse Anaplastic Wilms Tumors (dawt) and Relapsed Favorable Histology Wilms Tumors (fhwt) $-806
93.855 A Phase 2b, Multicenter, Randomized, Open-Label, Assessor-Blinded Superiority Study to Compare the Efficacy and Safety of Dalbavancin to Standard of Care Antibiotic Therapy for the Completion of Treatment of Patients with Complicated S. Aureus Bacteremia $-2,875
93.395 Southwest Oncology Group Network Group Operations Center of the Nctn $-16,000
20.U00 Crash Risk Associated with Drug and Alcohol Use by Drivers in Fatal and Serious Injury Crashes $-56,663
93.994 Perinatal/neonatal Outreach Coordinator Program Region III - Maternal and Child Health Services Block Grant to States $-66,621