Finding 574755 (2024-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-08-27
Audit: 365058
Organization: Corewell Health & Affiliates (MI)

AI Summary

  • Core Issue: Incorrect project dates and federal expenditure amounts were reported in one of the two Federal Financial Reports (FFRs) submitted for FY 2024.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and 2 CFR 200.328(c) regarding accurate reporting and internal controls over federal awards.
  • Recommended Follow-Up: Strengthen internal controls and establish a protocol for reviewing FFR data before submission to ensure accuracy and compliance.

Finding Text

Identification of the Federal Program: Federal Agency and Program Name: U.S. Department of Health and Human Services Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities Award Year(s): 2024 Assistance Listing #: 93.817 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR 200.303 requires that 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR section 200.328(c) requires that recipients of Federal funding “must submit financial reports as required by the Federal award.” Condition: For one of the two Federal Financial Reports (FFRs) submitted in FY 2024, incorrect project/grant period dates and federal share of expenditures amount was reported in the FFR. Cause: Corewell did not have sufficient internal controls to follow the FFR instructions and report the correct amounts. Effect or Potential Effect: The information reported and provided to the Federal awarding agency could be incomplete or inaccurate. Questioned Costs: None Context: Corewell submitted 2 FFR reports in FY 2024. The FFR instructions required reporting the cumulative Federal share of expenditures amount ($2,253,211) from the date of inception of the award (9/30/2022) through the end date of the reporting period specified. However, Corewell reported only the current period expenditures ($933,054) for the current grant year and consequently, this error also resulted in incorrect amount reported for Unliquidated balance of Federal funds. The total federal expenditures for HPP for FY 2024 were $1,292,999. Identification as a Repeat Finding: This is not a repeat finding.Recommendation: We recommend management strengthen its internal controls and procedures over review of the data in the FFR prior to submission of the report(s). Views of Responsible Officials: Management will develop a written protocol and tracking matrix to record and track all federally funded projects that report through the Payment Management System (PMS) to ensure the correct period of performance report is created and a second level of review performed on a timely basis in accordance with sponsor requirements prior to submission.

Corrective Action Plan

Finding 2024-002 Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services (HHS) Assistance Listing: 93.817 Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities Pass-Through Grantor: Not applicable Award Number: U3REP220676 Award Period: 9/30/2024-9/29/2025 Summary of Finding: For one of the two Federal Financial Reports (FFRs) submitted in FY 2024, incorrect project/grant period dates and federal share of expenditures amount was reported in the FFR. Two FFR reports were submitted in FY 2024. The FFR instructions required reporting the cumulative Federal share of expenditures amount ($2,253,211) from the date of inception of the award (9/30/2022) through the end date of the reporting period specified. However, Corewell reported only the current period expenditures ($933,054) for the current grant year and consequently, this error also resulted in incorrect amounts reported for the Unliquidated balance of Federal funds. The total federal expenditures for HPP for FY 2024 were $1,292,999. Corrective Action Plan: Leadership acknowledges the need for more robust deliverable tracking and review of Federal Financial Reports (FFRs) prior to submission. A written protocol and tracking matrix will be developed to record and track all federally funded projects that report through the Payment Management System (PMS) to ensure the correct period of performance report is created and a second level of review performed on a timely basis in accordance with sponsor requirements prior to submission. Individuals responsible for corrective action: Brittany Kruse, Vice President Finance and Assistant Controller David Ross, Director, Research Finance and Analysis Timing of corrective action: September 1, 2025, and going forward

Categories

Reporting

Other Findings in this Audit

  • 574756 2024-001
    Material Weakness
  • 574757 2024-003
    Material Weakness
  • 1151197 2024-002
    Significant Deficiency
  • 1151198 2024-001
    Material Weakness
  • 1151199 2024-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $7.80M
93.817 Hospital Preparedness Program (hpp) Ebola Preparedness and Response Activities $1.29M
93.926 Healthy Start Initiative $1.11M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $1.04M
93.493 Congressional Directives $505,000
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $349,873
12.420 Military Medical Research and Development $336,625
93.914 Hiv Emergency Relief Project Grants $322,578
93.855 Allergy and Infectious Diseases Research $249,754
93.217 Family Planning Services $177,765
93.307 Minority Health and Health Disparities Research $165,150
93.136 Injury Prevention and Control Research and State and Community Based Programs $161,673
93.940 Hiv Prevention Activities Health Department Based $158,111
93.865 Child Health and Human Development Extramural Research $151,953
93.110 Maternal and Child Health Federal Consolidated Programs $149,992
93.304 Racial and Ethnic Approaches to Community Health $147,899
93.516 Public Health Training Centers Program $129,807
21.027 Coronavirus State and Local Fiscal Recovery Funds $112,167
93.276 Drug-Free Communities Support Program Grants $108,357
93.889 National Bioterrorism Hospital Preparedness Program $87,801
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $70,739
93.778 Medical Assistance Program $66,965
93.788 Opioid Str $65,897
93.835 Planning Grant for Healthcare and Public Health Sector Cybersecurity Information Sharing $62,282
93.994 Maternal and Child Health Services Block Grant to the States $59,488
93.866 Aging Research $51,385
93.395 Cancer Treatment Research $47,025
93.226 Research on Healthcare Costs, Quality and Outcomes $44,407
93.178 Nursing Workforce Diversity $42,165
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $35,736
93.959 Block Grants for Prevention and Treatment of Substance Abuse $27,611
93.859 Biomedical Research and Research Training $27,338
93.310 Trans-Nih Research Support $25,540
93.838 Lung Diseases Research $24,000
12.300 Basic and Applied Scientific Research $19,903
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $19,258
93.988 Cooperative Agreements for Diabetes Control Programs $19,121
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $17,371
93.397 Cancer Centers Support Grants $16,978
93.837 Cardiovascular Diseases Research $16,500
93.867 Vision Research $11,231
93.213 Research and Training in Complementary and Integrative Health $10,478
93.301 Small Rural Hospital Improvement Grant Program $5,205
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $5,095
93.113 Environmental Health $4,062
93.839 Blood Diseases and Resources Research $3,734
93.393 Cancer Cause and Prevention Research $3,520
93.399 Cancer Control $3,000
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $2,340
93.279 Drug Use and Addiction Research Programs $2,000
93.825 National Ebola Training and Education Center (netec) $1,464
93.361 Nursing Research $848