Finding Text
Finding Number: 2022-002 Finding Type: Federal award finding Federal Assistance Listing No.: n/a Program Name: R&D Cluster Federal Agency: Agency for Healthcare Research and Quality Pass-Through Entity: n/a Grant Number: 93-75Q80122C00002 & 93-HHSA290201700003C Federal Award Year: 2022 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: Yes Compliance requirement: Allowable Costs and Cash Management Questions Costs: Yes Repeat Finding: No Criteria: Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart E ? Cost Principles provides that costs charges to a federal award must be adequately documented. Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, requires that an organization establish and maintain effective controls to minimize the time elapsing between the receipt of federal funds and the disbursement of such funds. Condition: During the audit, we noted that that the Foundation requested reimbursement for costs incurred based on a signed Memorandum of Understanding for the provision of services to be provided by the VAPORHCS. Although the services were provided in accordance with the Memorandum of Understanding, the VAPORHCS never invoiced the Foundation for the services it provided. Subsequent to year-end, the questioned costs were resolved with the funds returned to the VAPORHCS. Cause: The Foundation did not have an effective system into place to monitor receipt of invoices and payments for services related to various Memorandums of Understanding entered into with the VAPORHCS. Effect: Costs charged were not properly documented. The Foundation could have accidently charged the federal agency for costs that had not been incurred. In addition, the Foundation did not comply with the requirements to minimize the time elapsing between the receipt of federal funds and the disbursement of such funds. Questioned Costs: $95,399. Audit Recommendation: We recommend that the organization implement procedures to ensure that reimbursement requests are based on actual invoices. Management?s Response: Explanation of disagreement with the audit finding. There is no disagreement with the audit findings. Action taken in response to the finding. Once this deficiency was identified, PVARF immediately contacted the VA Portland Health Care System to determine if invoicing would be forthcoming. When it was made clear that there was no forthcoming invoicing, the sponsor was contacted to determine refund steps. Ultimately, the funds that were inappropriately billed were returned to the agency. Action Plan. In addition to ensuring effective communication between the stakeholders, PVARF implemented standard follow-up protocols to make certain VAPORHCS is invoicing PVARF timely. PVARF is in the process of implementing a project management platform that will effectively and efficiently manage major milestones such as invoicing for grants, contracts, and clinical trials. It was also made clear to PVARF administrative staff that there will be no billing ahead of the receipt of invoices on any agreements, and that doing so is a breech of the executed contract. Name(s) of the contact people responsible for correction action. Admin Staff Team Plan completion date for corrective action plan. July 31, 2023