Finding Text
Finding 2022-002 Significant deficiency in internal control over compliance for special tests and provisions. Federal Agency: Department of Defense Pass-Through: N/A Assistance Listing Number: 12.750 Assistance Listing Name: Uniformed Services University Medical Research Projects Award Number: HU00011920056, HU00011920022, HU00011920070 Period of Award: 10/1/19 - 9/30/23, 8/17/18 - 9/30/22, 9/16/19 - 9/15/23 Criteria The National Institutes of Health and the Department of Defense require prior approval for a significant change in the status of key personnel including but not limited to withdrawal from the project; absence for any continuous period of 3 months or more; reduction of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award. Condition/Context The Foundation?s internal controls require management to obtain prior approval for any significant changes or shortfalls of 25 percent or more of stated level of efforts in key personnel, to the award sponsor. During our testing, out of 19 grants tested, we noted 3 grants with instances where individuals identified as key personnel in the agreement either left the Foundation or had over 25% shortfall of level of efforts, and the sponsor was not timely notified. Our sample was not a statistical sample. Cause The Foundation?s internal controls related to notifying the sponsor of changes in key personnel was not consistently applied. Effect or Potential Effect Deficiencies in internal controls related to key personnel could result in material noncompliance. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendation We recommend changes in key personnel be communicated to the award sponsor prior to the change or as soon as practically possible. We also recommend additional training and/or monitoring to ensure the Foundation?s controls related to notifying the sponsor of changes in key personnel are consistently applied. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.