Finding 2023-001 – Segregation of Duties
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which is reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Management Response: In August of 2022, the RTOG Foundation Inc. executed a Financial Management Services Agreement with the NSABP Foundation Inc. to provide oversight and management of financial statement preparation. The independent resources provided under this contract include day to day financial support from a Director of Finance with a supporting staff of accountants, financial analysts, and top-level oversight by a Senior Director of Finance with extensive experience in the financial management of clinical trials. The prior project manager referenced above has relinquished all financial accounting responsibilities and appropriate segregation of duties has been achieved, including, but not limited to, internal controls surrounding the payment of invoices. Routine financial analysis, account reconciliations, treasury functions, audit support and budgeting are also included under this services agreement. Monthly financial results are reviewed with the Board of Directors at regularly scheduled meetings.