Finding 59678 (2022-001)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 55776
Organization: Advocate Aurora Health, Inc. (IL)

AI Summary

  • Core Issue: Internal controls for effort certification on salaries and wages are inadequate, leading to potential unallowable charges to the R&D Cluster.
  • Impacted Requirements: Compliance with Uniform Guidance and 45 CFR Part 75 regarding timely and complete effort certification is not being met.
  • Recommended Follow-Up: Implement robust internal controls to ensure 100% effort is certified monthly and reviewed by knowledgeable individuals promptly.

Finding Text

Finding 2022-001 Information on the Federal Program: Federal Agency: United States Department of Health and Human Services Assistance Listing No.: Research and Development Cluster (various Assistance Listings) Award Periods: Various Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): The Uniform Guidance 2 CFR Section 200.303 states, ?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 or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 45 CFR Part 75 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, Appendix IX to Part 75 ? Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts with Hospitals, states: ?Charges for salaries and wages of individuals other than members of the professional staff will be supported by daily time and attendance and payroll distribution records. For members of the professional staff, current and reasonable estimates of the percentage distribution of their total effort may be used as support in the absence of actual time records. In order to qualify as current and reasonable, estimates must be made no later than one month (though not necessarily a calendar month) after the month in which the services were performed. Estimates determined before the performance of services, such as budget estimates on a monthly, quarterly, or yearly basis do not qualify as estimates of effort spent.? Section III ? Federal Award Findings and Questioned Costs (continued) Condition: Charges of salaries and wages to the R&D Cluster were not consistently reviewed by a knowledgeable individual or not certified timely. In addition, certain individuals? effort certification did not account for 100% of their effort (R&D and institutional). Cause: The Organization does have not internal controls in place to monitor that 100% of effort is certified, and the effort is certified timely and reviewed and approved by a knowledgeable individual. Effect or Potential Effect: Charges for salaries and wages were charged to the R&D Cluster for individuals who did not certify their effort or 100% of their effort. In addition, the lack of internal controls over the review and approval of effort certification could result in unallowable charges for salaries and wages to be charged to the program. Questioned Costs: None Context: We selected a sample of 40 salaries and wages totaling $68,789 for the year ended December 31, 2022. We concluded effort certifications did not include 100% effort and were not reviewed and approved for 20 selections ($40,817). We also noted one instance ($1,965) which was not reviewed and approved timely. Total salaries and wages, fringe benefits, and indirect costs related to the R&D Cluster were $2,786,348 for the year ended December 31, 2022. Total R&D expenditures recorded on the Schedule of Expenditures of Federal Awards (the Schedule) are $3,323,540 for the year ended December 31, 2022. Section III ? Federal Award Findings and Questioned Costs (continued) Identification as a Repeat Finding, if Applicable: This is a repeat finding; see 2021-002. Recommendation: The Organization should implement internal controls to require individuals to certify 100% of their effort on a monthly basis to ensure that salaries and wages are based on actual efforts spent. The Organization should design and implement internal controls to review and approve the effort certified by an individual with knowledge of the employee?s effort on a timely basis. Management?s Response: The Office of Sponsored Research (OSR) committed in the 2020 Corrective Action Plan to implement a paper format effort certification process beginning March 2022. This process was fully implemented by the end of fiscal 2022. Also in 2022, Advocate Aurora Research Institute employees were transferred and integrated under one financial system. The integration of this system supports the monitoring of 100% of total effort. The OSR will also continue to utilize a paper effort certification process. The OSR team will generate effort certification form, distribute the effort certification form to the appropriate team member for manual or electronic signature and obtain a secondary approval signature from an individual who has first-hand knowledge of the team member?s activities. All completed effort certification forms will be verified and initialed by a third individual. Effort certification logs will be maintained to ensure that all effort certifications are completed within 30 days. Completed effort certification forms will be maintained within OSR.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 59655 2022-001
    Material Weakness
  • 59656 2022-001
    Material Weakness Repeat
  • 59657 2022-001
    Material Weakness Repeat
  • 59658 2022-001
    Material Weakness Repeat
  • 59659 2022-001
    Material Weakness Repeat
  • 59660 2022-001
    Material Weakness Repeat
  • 59661 2022-001
    Material Weakness Repeat
  • 59662 2022-001
    Material Weakness Repeat
  • 59663 2022-001
    Material Weakness Repeat
  • 59664 2022-001
    Material Weakness Repeat
  • 59665 2022-001
    Material Weakness Repeat
  • 59666 2022-001
    Material Weakness Repeat
  • 59667 2022-001
    Material Weakness Repeat
  • 59668 2022-001
    Material Weakness Repeat
  • 59669 2022-001
    Material Weakness Repeat
  • 59670 2022-002
    Material Weakness
  • 59671 2022-001
    Material Weakness Repeat
  • 59672 2022-001
    Material Weakness Repeat
  • 59673 2022-001
    Material Weakness Repeat
  • 59674 2022-001
    Material Weakness Repeat
  • 59675 2022-001
    Material Weakness Repeat
  • 59676 2022-001
    Material Weakness Repeat
  • 59677 2022-001
    Material Weakness Repeat
  • 59679 2022-001
    Material Weakness Repeat
  • 59680 2022-001
    Material Weakness Repeat
  • 636097 2022-001
    Material Weakness
  • 636098 2022-001
    Material Weakness Repeat
  • 636099 2022-001
    Material Weakness Repeat
  • 636100 2022-001
    Material Weakness Repeat
  • 636101 2022-001
    Material Weakness Repeat
  • 636102 2022-001
    Material Weakness Repeat
  • 636103 2022-001
    Material Weakness Repeat
  • 636104 2022-001
    Material Weakness Repeat
  • 636105 2022-001
    Material Weakness Repeat
  • 636106 2022-001
    Material Weakness Repeat
  • 636107 2022-001
    Material Weakness Repeat
  • 636108 2022-001
    Material Weakness Repeat
  • 636109 2022-001
    Material Weakness Repeat
  • 636110 2022-001
    Material Weakness Repeat
  • 636111 2022-001
    Material Weakness Repeat
  • 636112 2022-002
    Material Weakness
  • 636113 2022-001
    Material Weakness Repeat
  • 636114 2022-001
    Material Weakness Repeat
  • 636115 2022-001
    Material Weakness Repeat
  • 636116 2022-001
    Material Weakness Repeat
  • 636117 2022-001
    Material Weakness Repeat
  • 636118 2022-001
    Material Weakness Repeat
  • 636119 2022-001
    Material Weakness Repeat
  • 636120 2022-001
    Material Weakness Repeat
  • 636121 2022-001
    Material Weakness Repeat
  • 636122 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $35.51M
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $34.35M
93.788 Opioid Str $747,335
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $588,032
21.027 Coronavirus State and Local Fiscal Recovery Funds $377,602
93.959 Block Grants for Prevention and Treatment of Substance Abuse $285,068
93.889 National Bioterrorism Hospital Preparedness Program $241,700
93.866 Aging Research $198,004
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $166,501
16.575 Crime Victim Assistance $159,830
93.958 Block Grants for Community Mental Health Services $133,506
93.307 Minority Health and Health Disparities Research $122,925
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $94,000
93.242 Mental Health Research Grants $89,204
93.399 Cancer Control $52,007
93.136 Injury Prevention and Control Research and State and Community Based Programs $40,694
93.865 Child Health and Human Development Extramural Research $34,897
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $30,360
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $26,925
93.279 Drug Abuse and Addiction Research Programs $22,704
93.393 Cancer Cause and Prevention Research $19,059
20.600 State and Community Highway Safety $17,539
93.566 Refugee and Entrant Assistance_state Administered Programs $16,062
16.754 Harold Rogers Prescription Drug Monitoring Program $9,151
93.226 Research on Healthcare Costs, Quality and Outcomes $8,776
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $8,191
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $6,616
93.837 Cardiovascular Diseases Research $5,700
10.555 National School Lunch Program $5,562
10.558 Child and Adult Care Food Program $1,272
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $479