Finding 616375 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 37679
Organization: The Rogosin Institute, Inc. (NY)
Auditor: Ernst & Young

AI Summary

  • Core Issue: The Institute lacks effective controls to ensure all vendors are screened for suspension and debarment before entering into transactions.
  • Impacted Requirements: This finding violates Title 2 U.S. Code of Federal Regulations, Part 200.303, which mandates effective internal controls for managing Federal awards.
  • Recommended Follow-Up: Management should improve the screening process to include all relevant vendors and subrecipients to ensure compliance with suspension and debarment requirements.

Finding Text

Finding 2022-002 ? I. Procurement and Suspension and Debarment Identification of the Federal Program: Grantor: Department of Defense, Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No. / FAIN / Pass-Through Entity (if applicable) / Pass-Through Entity Identifying Number (if applicable): 12.420 / W81XWH180620 93.847 / RC2DK125960 93.847 / R24DK106743 93.847 / UC2DK126021 / MDI Biological Laboratory / UC2DK126021-02/Rogosin 93.847 / R56DK125960 / UT Southwestern Medical Center / GMO210101 PO0000002155 93.847 / R01DK131050 / Joan & Sanford I. Weill Medical College of Cornell University / 213209 / 225880 93.847 / U01DK123786 / University of Washington / UWSC11731 93.847 / R01DK115468 / University of Washington / UWSC10982 93.847 / U01DK123813 / Trustees of the University of Pennsylvania / 577985 93.855 / R21AI164093 / Joan & Sanford I. Weill Medical College of Cornell University / 211581 / 222908 Criteria or Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, ?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.? Condition: Management was unable to provide evidence of a control being consistently performed to address the risk that the Institute may enter into a covered transaction with an entity that is suspended, debarred, or otherwise excluded. Cause: Management has established a suspension and debarment screening process for activities associated with the Institute?s Research and Development Cluster. However, the process is not designed effectively to ensure all entities with which the Institute may enter into a covered transaction are included in the screening process. Effect or Potential Effect: The lack of an effective control over suspension and debarment has the potential to result in noncompliance with the requirement. Questioned Costs: None. Context: The Institute assesses vendors upon initial entry into the Institute?s payment system and performs a monthly screening of its vendors to determine if they are either suspended, debarred or otherwise excluded. However, in a sample of seventeen vendors with activity associated with the Institute?s Research and Development Cluster, we noted that four vendors were not included in the Institute?s monthly screening process. In our testing, we noted no instances of noncompliance with suspension and debarment standards in the sample of seventeen vendors selected. Identification as a repeat finding: This finding was reported as finding 2021-003 in the prior year. Recommendation: Management should enhance the design of its control to ensure that all vendors and subrecipients associated with the Institute?s Research and Development Cluster are subject to the monthly suspension and debarment screening process. Views of Responsible Officials: Management concurs with this audit finding and will enhance the suspension and debarment review process and controls to meet the requirements of 2 CFR part 200.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 39933 2022-002
    Significant Deficiency Repeat
  • 39934 2022-001
    Material Weakness Repeat
  • 39935 2022-002
    Significant Deficiency Repeat
  • 39936 2022-002
    Significant Deficiency Repeat
  • 39937 2022-002
    Significant Deficiency Repeat
  • 39938 2022-002
    Significant Deficiency Repeat
  • 39939 2022-002
    Significant Deficiency Repeat
  • 39940 2022-002
    Significant Deficiency Repeat
  • 39941 2022-002
    Significant Deficiency Repeat
  • 39942 2022-002
    Significant Deficiency Repeat
  • 616376 2022-001
    Material Weakness Repeat
  • 616377 2022-002
    Significant Deficiency Repeat
  • 616378 2022-002
    Significant Deficiency Repeat
  • 616379 2022-002
    Significant Deficiency Repeat
  • 616380 2022-002
    Significant Deficiency Repeat
  • 616381 2022-002
    Significant Deficiency Repeat
  • 616382 2022-002
    Significant Deficiency Repeat
  • 616383 2022-002
    Significant Deficiency Repeat
  • 616384 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $239,162
12.420 Military Medical Research and Development $75,897
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $34,671
93.855 Allergy, Immunology and Transplantation Research $19,527