Finding 382708 (2023-002)

Finding 2023-002 – Internal Control Deficiency Over Activities Allowed or Unallowed and Activities Allowed/Allowable Costs Identification of the federal program: Federal Grantor: Department of Homeland Security; Federal Emergency Management Agency (FEMA) Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Award Period of Performance: January 20, 2020–various dates through 2023 depending on the individual project worksheets Criteria or Specific Requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) 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: Per discussion with management, OU Medicine, Inc. has processes and internal controls in place to ensure personnel expenses submitted to the FEMA program were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the expenses to ensure the expenses comply with the terms and conditions of the award. However, management did not consistently retain documentation evidencing the performance of these controls. Cause: OU Medicine, Inc. did not consistently retain documentation to evidence the performance of internal controls over personnel expenses charged to the federal program. Effect or potential effect: There is no consistent documentation to support the performance of internal controls for costs charged to the federal program. Questioned Costs: $0 Context: Total FEMA expenditures for Assistance Listing 97.036 were $1,818,602, of which $277,283 were personnel costs, of which management did not retain documentation of the performance of controls. Identification as a repeat finding, if applicable: The finding is a repeat finding of 2022-001. Recommendation: OU Medicine, Inc. should refine its process and retain documentation evidencing that management reviewed personnel expenses charged to the federal program to ensure the cost is allowable. View of Responsible Officials: OU Medicine, Inc. agrees with the finding; however, the program has ended. Should OU Medicine, Inc. receive funding in the future, management will implement procedures to ensure documentation of executing the controls is retained.