Finding 555172 (2024-003)

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Requirement
L
Questioned Costs
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Year
2024
Accepted
2025-04-16

AI Summary

  • Core Issue: An incorrect progress report was submitted to the grantor due to inadequate internal controls.
  • Impacted Requirements: Compliance with Title 2 U.S. Code of Federal Regulations Part 200, which mandates supervisory review of financial reports.
  • Recommended Follow-Up: Establish formal internal control policies for supervisory review and approval of reports, ensuring documentation of all reviews.

Finding Text

Finding 2024-003 - Reporting Idenfication of federal program: Assistance Listing No. 93.493 - Congressional Directives Criteria or specific requirement: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards requires that the auditee maintain internal control over financial reporting which includes supervisory review of reports prepared and submitted to the grantor to assure accuracy and completeness of data included in the reports. Condition: We noted an incorrect progress report being submitted to the grantor. Cause: Formal internal control policies and procedures requiring supervisory review of reports have not been established. Effect or potential effect: The lack of adequate internal control policies and procedures requiring timely supervisory review of reports filed with grantor may result in inaccurate information being reported and non-compliance with program requirements. This finding resulted in an incorrect progress report being submitted to the grantor. Questioned cost: not applicable. Context: An incorrect progress report was submitted to the grantor. Recommendation: We recommend that the System establish formal internal control policies and procedures requiring supervisory review and approval of all reports filed with the grantor to assure the accuracy and completeness of data included in such reports. All such reviews and approvals should be properly documented. Views of responsible officials: The System concurs with this finding. See page 54 for corrective action plan.

Corrective Action Plan

Identifying Number: 2024-003 Finding: Reporting Context: An incorrect progress report was submitted to the grantor. Corrective Actions Taken or Planned: The Director of the Office of Sponsored Programs and the Manager of Sponsored Programs will develop a standardized document checklist for all high-value expenditures. This checklist will require all Sponsored Programs analysts to submit complete documentation with expense reports and proof of payment and have their respective immediate supervisor/manager review for compliance before final approval by the Director. a. Implementing organizational cjanges such as updated policies and/or procedures b. Educating the team(s) and/or Department(s) on internal controls, processes and accuracy best practices during the Grant management process c. Oversight of drawdown requests by the Director of Sponsored Programs to ensure accuracy of request Planning Process: Compliance with Regulations: The Director and Manager from Sponsored Programs will ensure the corrective actions align with applicable federal grant regulations and guidelines. We will create: - Implement internal controls, with the Director and Manager from Sponsored Programs developing checks and balances at the end of each month to ensure compliance in all the grant's portfolio. - Oversight of all drawdown requests, ensuring complete and accurate supporting documentation. Communication: The Director and Manager from Sponsored Programs will communicate the corrective action plan to all relevant staff and stakeholders. Follow-up: The Director and Manager from Sponsored Programs will regularly monitor progress and adjust to resolve any inefficiencies. Training: The Director and Manager from Sponsored Programs will work on the development and delivery of mandatory training sessions for all Sponsored Programs relevant staff. This will include (not limited to): - Retrain on updated policies and procedures (OSP team, Departments and stakeholders, if applicable) - Retrain on workflows and system (OSP team, Departments and stakeholders, if applicable) - Retrain on process improvement (OSP team, Departments and stakeholders, if applicable) Policy Updates: Revision of existing policies or creation of new ones to clarify procedures. System Enhacements: Implementing new software/program that improves data accuracy and compliance in all Federal/State and Local Grants throughout Nicklaus Children's Hospital. Monitoring and Oversight: The Director and Manager from the Sponsored Programs will monitor transactions and reporting processed more frequesntly. Deadline for Implementation: Immediate Action: The Director of Sponsored Programs transitioned the staff member responsible for the findings to an area where their expertise is most valuable. This CAPA will take effect immediately and be fully implemented within six weeks by April 07, 2025, allowing time to create/revise SOPs, Working Practice Guidelines (WPGs), Checklists and training/retraining sessions for stakeholders and OSP team members.

Categories

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.994 Maternal and Child Health Services Block Grant to the States $999,876
93.493 Congressional Directives $695,098
93.059 Training in General, Pediatric, and Public Health Dentistry $491,300
93.307 Minority Health and Health Disparities Research $168,512
93.395 Cancer Treatment Research $98,182
93.110 National Organizations of State and Local Officials $15,000
93.865 Child Health and Human Development Extramural Research $12,000
93.242 Mental Health Research Grants $3,360
93.838 Lung Diseases Research $2,000