Finding 548398 (2024-003)

-
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: Cheshire Medical Center failed to notify the New Hampshire DHHS about key personnel changes for the Opioid STR awards.
  • Impacted Requirements: Changes in key personnel require prior written approval as per 2 CFR 200.308 and the award terms.
  • Recommended Follow-Up: Implement a control system to ensure timely communication and approval requests for any personnel changes.

Finding Text

Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services Award Names: Substance Use Disorder Treatment and Recovery Award Numbers: Cheshire Medical Center 2019-BDAS-05-ACCES-04, 05-95-92-920510-7040-5007, RFP-2018-BDAS-05-INTEG Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2023-2024 Pass-through entity: New Hampshire Department of Health and Human Services Criteria 2 CFR 200.308 Revision of budget and program plans requires a recipient or subrecipient to request prior written approval from the Federal agency or pass-through entity for changes in key personnel (including employees and contractors) that are identified by name or position in the Federal award. Additionally, the terms of the Opioid STR award agreements at Cheshire Medical Center require changes in staffing, whether temporary or long term, to be provided to the New Hampshire Department of Health and Human Services (DHHS) for approval, 30 calendar days before making the change. Condition In testing conformity with the compliance requirements for key personnel, we selected 4 of the key personnel changes that occurred on the Cheshire Medical Center Opioid STR awards which included key personnel that changed roles or resigned from the System in fiscal year 2024. Management identified replacement key personnel to participate in the grant; however, management did not notify DHHS and did not obtain approval from DHHS regarding the changes. Cause Management did not have a control in place to notify DHHS and request approval for key personnel changes. Effect The granting agency was unaware of key changes made to personnel on the award and may have not concurred with the individual selected to fill the given role(s). Questioned Costs None noted. Recommendation We recommend that management communicate with their agency contacts regarding this matter and implement a control that monitors the key personnel assigned to the grant to ensure that they are notifying the agency of any changes in status and obtaining approval from the agency in a timely manner.

Corrective Action Plan

Management agrees with the finding related to Key Personnel Change Approval at our member, Cheshire Medical Center. The post-award management of this grant is currently handled outside of the Dartmouth Health Research Finance and Post-Award department. Management aims to centralize this function by December 31, 2025. In the interim, Dartmouth Health Management will provide training to award operational staff to implement policies that align with the centrally managed awards by June 30, 2025. Specifically, the Member will conduct a monthly review of key personnel efforts to identify any potential changes that require notification to the New Hampshire Department of Health and Human Services or any award sponsor in which the Key Personnel Change compliance requirement is required. Leadership Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: June 30, 2025

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $3.19M
17.720 Disability Employment Policy Development $1.05M
93.969 Pphf Geriatric Education Centers $914,313
17.268 H-1b Job Training Grants $840,402
93.087 Enhance Safety of Children Affected by Substance Abuse $787,352
93.788 Opioid Str $744,673
93.800 Organized Approaches to Increase Colorectal Cancer Screening $686,821
93.069 Public Health Emergency Preparedness $653,662
93.186 National Research Service Award in Primary Care Medicine $625,462
93.307 Minority Health and Health Disparities Research $570,661
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $463,310
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $400,226
93.958 Block Grants for Community Mental Health Services $376,504
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $357,751
93.213 Research and Training in Complementary and Integrative Health $326,712
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $306,282
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $304,399
12.007 Military Health Services Research (mhsr) $298,107
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $289,668
21.027 Coronavirus State and Local Fiscal Recovery Funds $280,206
93.155 Rural Health Research Centers $251,842
93.493 Congressional Directives $250,000
93.850 Improving Epilepsy Programs, Services, and Outcomes Through National Partnerships $246,198
93.127 Emergency Medical Services for Children $230,377
93.U01 Greater Monadnock Regional Public Health Network Services $203,244
93.778 Medical Assistance Program $191,314
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $187,836
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $179,865
93.398 Cancer Research Manpower $169,631
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $161,812
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $153,744
93.268 Immunization Cooperative Agreements $136,332
93.478 Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees $128,779
93.991 Preventive Health and Health Services Block Grant $93,359
93.113 Environmental Health $89,605
93.397 Cancer Centers Support Grants $81,393
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $77,997
93.145 Hiv-Related Training and Technical Assistance $71,324
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $67,536
20.600 State and Community Highway Safety $64,733
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $62,240
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $56,164
93.879 Medical Library Assistance $51,265
93.310 Trans-Nih Research Support $49,873
93.276 Drug-Free Communities Support Program Grants $47,859
16.758 Improving the Investigation and Prosecution of Child Abuse and the Regional and Local Children's Advocacy Centers $45,013
93.838 Lung Diseases Research $34,859
93.837 Cardiovascular Diseases Research $34,234
93.395 Cancer Treatment Research $31,703
93.865 Child Health and Human Development Extramural Research $31,495
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $28,750
93.393 Cancer Cause and Prevention Research $26,804
12.599 Congressionally Directed Assistance $24,472
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $24,342
93.061 Innovations in Applied Public Health Research $23,015
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $22,499
93.110 Maternal and Child Health Federal Consolidated Programs $20,464
93.136 Injury Prevention and Control Research and State and Community Based Programs $20,433
93.866 Aging Research $19,950
93.855 Allergy and Infectious Diseases Research $19,733
93.173 Research Related to Deafness and Communication Disorders $15,838
93.350 National Center for Advancing Translational Sciences $15,412
93.732 Mental and Behavioral Health Education and Training Grants $14,365
10.558 Child and Adult Care Food Program $13,446
93.301 Small Rural Hospital Improvement Grant Program $13,312
93.859 Biomedical Research and Research Training $12,883
93.867 Vision Research $11,697
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $11,466
93.989 International Research and Research Training $10,571
93.059 Training in General, Pediatric, and Public Health Dentistry $9,261
93.959 Block Grants for Prevention and Treatment of Substance Abuse $8,768
93.121 Oral Diseases and Disorders Research $8,016
93.396 Cancer Biology Research $7,389
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $6,273
93.226 Research on Healthcare Costs, Quality and Outcomes $4,077
12.420 Military Medical Research and Development $3,743
10.902 Soil and Water Conservation $3,478
93.761 Evidence-Based Falls Prevention Programs Financed Solely by Prevention and Public Health Funds (pphf) $2,525
93.394 Cancer Detection and Diagnosis Research $1,389
93.242 Mental Health Research Grants $1,230
93.279 Drug Use and Addiction Research Programs $1,055