Finding 496394 (2023-002)

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. Cause The Foundation’s internal controls related to notifying the sponsor of changes in key personnel was not consistently applied resulting in non-compliance. Effect or Potential Effect Deficiencies in internal controls related to key personnel could result in material noncompliance. Questioned Costs None. Repeat Finding Yes. 2022-002 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.