Finding Text
Finding 2023-003 – A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and H. Period of Performance
Identification of the federal program:
Federal Agency: U.S. Department of Health and Human Services
Federal Program: Research and Development Cluster (Assistance Listing Nos. 93.395 and 93.399)
BJC HealthCare Location: Missouri Baptist Medical Center
Pass-Through Entities and Award Numbers: Pass-Through Award Periods:
Brigham and Women’s Hospital, Inc./120870 (Amendment 1)
Brigham and Women’s Hospital, Inc./120870 03/01/2023–02/29/2024
03/01/2022–02/28/2023
Decatur Memorial Hospital/None 08/01/2022–07/31/2023; 08/01/2023–07/31/2024
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and 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:
Management reviews and approves Effort Certification Reports (ECRs) for allowability and period of performance, including determining whether adjustments were required and appropriate. Evidence of review and approval was not consistently retained for ECRs.
Cause:
Due to employee turnover, evidence of review and approval over the ECRs by the appropriate Grant Management Office personnel was not consistently retained during the fiscal year.
Effect or potential effect:
Unallowable expenses could be charged to the Research and Development Cluster program.
Questioned costs:
None.
Context:
Total Research and Development Cluster expenditures reported on the schedule of expenditures of federal awards are $1,125,092 for the year ended December 31, 2023. Of this amount, payroll costs totaled $666,648 and fringe benefit costs totaled $184,759.
Identification as a repeat finding:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure that established internal controls over the review and approval of effort reports are consistently followed.
Views of responsible officials:
BJC agrees with the findings as reported. BJC is committed to complying with program requirements and meeting program objectives as defined in Section 200.303(a) of the Uniform Guidance, regarding auditee internal controls. To facilitate these requirements, BJC will review and strengthen current controls and documentation to ensure that all ECRs are appropriately approved and documentation of the approval is retained.