FAC Explorer

Finding 538980 (2024-003)

Significant Deficiency Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349645
Organization: Morehouse School of Medicine, Inc., Subsidiary and Affiliate (GA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The School lacks proper documentation and oversight for payroll costs charged to federal programs, leading to compliance failures.
  • Impacted Requirements: Federal grant requirements for allowable costs, specifically regarding accurate level of effort certifications for salaries and wages.
  • Recommended Follow-Up: Implement improved internal controls and transition to an automated effort reporting system by June 30, 2025, to ensure timely compliance.

Finding Text

Finding 2024-003 Federal Program Information: Research and Development Cluster (ALN: 12.420), The National COVID-19 Resiliency Network (“NCRN”): Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund (“HEERF”) (ALN: 84.425J), and Title III Part B Strengthening Historically Black Colleges and Universities (“Title III”) (ALN: 84.031) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 1 of 25 selected Research and Development Cluster expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program. • For 1 of 25 selected NCRN expenditures, level of effort certification did not accurately reflect time and effort charged to the federal program. • For 12 of 25 selected HEERF expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program. • For 1 of 25 selected Title III expenditures, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Insufficient administrative oversight and internal controls with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 15 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2023-005 in the 2023 report. Recommendation: We recommend that the School adhere to its procedures and internal controls over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 538975 2024-001
    Significant Deficiency Repeat
  • 538976 2024-002
    Significant Deficiency Repeat
  • 538977 2024-002
    Significant Deficiency Repeat
  • 538978 2024-003
    Significant Deficiency Repeat
  • 538979 2024-003
    Significant Deficiency Repeat
  • 538981 2024-003
    Significant Deficiency Repeat
  • 1115417 2024-001
    Significant Deficiency Repeat
  • 1115418 2024-002
    Significant Deficiency Repeat
  • 1115419 2024-002
    Significant Deficiency Repeat
  • 1115420 2024-003
    Significant Deficiency Repeat
  • 1115421 2024-003
    Significant Deficiency Repeat
  • 1115422 2024-003
    Significant Deficiency Repeat
  • 1115423 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $51.19M
84.425 Education Stabilization Fund $37.93M
84.031 Higher Education Institutional Aid $18.61M
93.647 Social Services Research and Demonstration $1.91M
93.838 Lung Diseases Research $1.84M
93.493 Congressional Directives $1.45M
11.028 Connecting Minority Communities Pilot Program $1.32M
93.397 Cancer Centers Support Grants $1.25M
93.172 Human Genome Research $1.03M
93.307 Minority Health and Health Disparities Research $890,721
93.516 Public Health Training Centers Program $836,777
93.011 National Organizations for State and Local Officials $675,634
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $583,679
93.865 Child Health and Human Development Extramural Research $541,938
93.393 Cancer Cause and Prevention Research $494,245
93.350 National Center for Advancing Translational Sciences $469,778
93.822 Health Careers Opportunity Program (hcop) $429,005
93.137 Community Programs to Improve Minority Health $325,337
93.117 Preventive Medicine Residency $305,385
93.145 Hiv-Related Training and Technical Assistance $303,220
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $291,963
93.297 Teenage Pregnancy Prevention Program $281,402
93.310 Trans-Nih Research Support $277,280
93.304 Racial and Ethnic Approaches to Community Health $260,265
93.884 Primary Care Training and Enhancement $258,181
93.113 Environmental Health $238,476
93.355 Public Health Informatics & Technology Workforce Development Program (the Phit Workforce Development Program) $229,945
93.361 Nursing Research $190,837
93.396 Cancer Biology Research $164,289
93.U01 Examining Legal Gaps in Sociodemographic Data with Disease/vaccination Reporting $140,277
93.855 Allergy and Infectious Diseases Research $138,232
93.958 Block Grants for Community Mental Health Services $123,870
93.U04 Office of Logistics and Office of Administration Cobb Scholars Program $120,912
93.279 Drug Use and Addiction Research Programs $108,155
93.266 Health Systems Strengthening and Hiv/aids Prevention, Care and Treatment Under the President's Emergency Plan for Aids Relief $105,535
32.006 Covid-19 Telehealth Program $104,980
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $103,403
93.107 Area Health Education Centers $88,647
93.859 Biomedical Research and Research Training $85,217
43.002 Aeronautics $83,187
10.855 Distance Learning and Telemedicine Loans and Grants $80,556
93.184 Disabilities Prevention $76,884
47.070 Computer and Information Science and Engineering $59,881
12.420 Military Medical Research and Development $56,473
93.U08 Precision Environmental and Health Equity Research $55,233
93.U03 Ipa Assignment - Miles-Richardson $53,623
93.110 Maternal and Child Health Federal Consolidated Programs $50,333
93.945 Assistance Programs for Chronic Disease Prevention and Control $46,851
47.084 Nsf Technology, Innovation, and Partnerships $43,609
93.638 Aca-Transforming Clinical Practice Initiative: Practice Transformation Networks (ptns) $43,536
93.U02 Evidence-Informed Interventions to Improve Provider Communication with Racial and Ethnic Minority Patients $37,195
93.839 Blood Diseases and Resources Research $35,432
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $34,995
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $31,589
93.273 Alcohol Research Programs $31,409
47.074 Biological Sciences $30,854
93.136 Injury Prevention and Control Research and State and Community Based Programs $27,000
64.054 Research and Development $24,114
93.631 Developmental Disabilities Projects of National Significance $23,757
93.456 Cdc Undergraduate Public Health Scholars Program (cups): A Public Health Experience to Expose Undergraduates Interested in Minority Health to Public Health and the Public Health Professions $22,731
12.U01 Discovering Diagnostics, Subtypes and Natural History of Traumatic Brain Injury (tbi) $20,929
93.866 Aging Research $19,307
14.889 Choice Neighborhoods Implementation Grants $18,472
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $16,493
93.867 Vision Research $13,640
93.959 Block Grants for Prevention and Treatment of Substance Abuse $12,994
93.399 Cancer Control $11,755
16.045 Community-Based Violence Intervention and Prevention Initiative $11,748
43.003 Exploration $10,438
93.394 Cancer Detection and Diagnosis Research $10,146
47.083 Integrative Activities $7,262
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $7,256
47.076 Stem Education (formerly Education and Human Resources) $7,172
93.395 Cancer Treatment Research $6,902
93.283 Centers for Disease Control and Prevention Investigations and Technical Assistance $6,014
93.U05 Data Training and Engagement for Academic Libraries Program $3,925
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $3,127
93.426 The National Cardiovascular Health Program $3,080
93.242 Mental Health Research Grants $2,340
93.U09 Recover Vital: A Platform Protocol for Evaluation of Interventions for Viral Persistence, Viral Reactivation, and Immune Dysregulation in Post Acute Sequelae of Sars-Cov-2 Infection $1,631
93.837 Cardiovascular Diseases Research $1,500
93.989 International Research and Research Training $985
93.U06 Home Automatic External Defibrillator Trial - H.a.t. $44
93.788 Opioid Str $9
93.U07 Cancer Information Service $8
93.129 Technical and Non-Financial Assistance to Health Centers $0
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $0