FAC Explorer

Finding 584370 (2023-005)

-
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-01-09
Audit: 10337
Organization: Morehouse School of Medicine, Inc., Subsidiary and Affiliate (GA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: Seven out of 100 employees lacked the necessary level of effort certifications to support payroll costs charged to federal programs.
  • Impacted Requirements: Compliance with federal grant requirements for allowable costs, specifically § 200.430, which mandates accurate records and internal controls for payroll expenses.
  • Recommended Follow-Up: Implement stronger monitoring of level of effort reporting and ensure timely certification of work hours by employees to comply with federal requirements.

Finding Text

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) 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 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight 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 4 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. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures 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. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

Categories

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

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $42.17M
84.031 Higher Education_institutional Aid $13.72M
84.425 Education Stabilization Fund $9.87M
93.647 Social Services Research and Demonstration $1.67M
93.397 Cancer Centers Support Grants $1.46M
93.297 Teenage Pregnancy Prevention Program $1.44M
93.838 Lung Diseases Research $1.34M
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $947,056
93.822 Health Careers Opportunity Program $874,121
93.516 Affordable Care Act (aca) Public Health Training Centers Program $710,237
93.350 National Center for Advancing Translational Sciences $634,498
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $371,862
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $370,468
93.310 Trans-Nih Research Support $333,279
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $329,693
47.083 Integrative Activities $328,940
93.958 Block Grants for Community Mental Health Services $301,797
93.266 Health Systems Strengthening and Hiv/aids Prevention, Care and Treatment Under the President's Emergency Plan for Aids Relief $284,634
47.074 Biological Sciences $277,610
93.145 Aids Education and Training Centers $260,137
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $237,381
93.307 Minority Health and Health Disparities Research $231,735
93.844 Acl Centers for Independent Living, Recovery Act $227,802
93.279 Drug Abuse and Addiction Research Programs $227,002
93.867 Vision Research $211,241
93.137 Community Programs to Improve Minority Health Grant Program $181,405
93.393 Cancer Cause and Prevention Research $180,996
93.959 Block Grants for Prevention and Treatment of Substance Abuse $177,084
10.855 Distance Learning and Telemedicine Loans and Grants $156,724
93.117 Preventive Medicine Residency $146,575
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $144,623
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $142,302
14.889 Choice Neighborhoods Implementation Grants $124,844
47.070 Computer and Information Science and Engineering $98,418
93.113 Environmental Health $77,336
11.028 Connecting Minority Communities Pilot Program $76,104
93.788 Opioid Str $71,734
93.837 Cardiovascular Diseases Research $67,207
93.638 Aca-Transforming Clinical Practice Initiative: Practice Transformation Networks (ptns) $66,508
93.000 Office of Logistics and Office of Administration Cobb Scholars Program $50,900
93.172 Human Genome Research $49,337
93.184 Disabilities Prevention $48,268
93.000 Evidence-Informed Interventions to Improve Provider Communication with Racial and Ethnic Minority Patients $44,156
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $41,612
47.076 Education and Human Resources $40,304
64.054 Research and Development $29,135
93.110 Maternal and Child Health Federal Consolidated Programs $29,121
93.011 National Organizations of State and Local Officials $24,506
93.855 Allergy, Immunology and Transplantation Research $23,765
93.866 Child Health and Human Development Extramural Research $19,280
93.989 International Research and Research Training $17,984
93.879 Medical Library Assistance $15,261
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 $12,874
93.839 Blood Diseases and Resources Research $9,496
12.420 Military Medical Research and Development $6,134
93.859 Biomedical Research and Research Training $6,104
93.129 Technical and Non-Financial Assistance to Health Centers $3,995
43.003 Exploration $3,971
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $3,559
93.242 Mental Health Research Grants $1,786
32.006 Covid-19 Telehealth Program $1,360
93.865 Child Health and Human Development Extramural Research $529