Finding 2023-002
Material weakness in internal controls and non-compliance related to special tests and provisions.
Federal Agency: Department of Defense
Pass-Through: N/A
Assistance Listing Number: 12.420
Assistance Listing Name: Military Medical Research and Development
Award Number: W81XWH-18-2-0048
Period of Award: September 15, 2018 - September 14, 2024
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
Period of Award: October 1, 2019 - September 30, 2024
Federal Agency: U.S. Department of Health and Human Services
Pass-Through: University of Utah
Assistance Listing Number: 93.213
Assistance Listing Name: Research & Training in Complementary & Alternative
Medicine
Award Number: 10055443-02
Period of Award: September 22, 2020 - August 31, 2024
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, from the
award sponsor. During our testing, out of 22 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.
Contact Person(s):
Kristen Bacon, Director, Finance and Accounting.
Corrective action planned:
Geneva implemented the following increased measures in FY23 -- LOE operating procedures and
JAMIS reports were developed to ensure that material LOE variances were detected, discussed,
and if applicable, escalated to the sponsor. The Finance Office will revisit current LOE reports
and if necessary, will enhance reporting to improve more visibility and completeness of LOE data
by program. The Finance Office will also conduct a refresher training. As stated in the FY22
audit, management believes that review of financial and LOE reporting are clearly defined,
documented, and are in compliance with accounting principles generally accepted in the United
States of America and sponsor requirements; however, management will seek to strengthen the
documentation, reporting, training, and communications between Finance and the Department of
Programs. If process deficiencies are identified or Standard Operating Procedures are not current,
updates will be made, and end user compliance training will be rolled out to ensure a clear
understanding.
Anticipated completion date
September 30, 2024