Finding 623817 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-07-10
Audit: 40905
Organization: The Geneva Foundation (WA)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls regarding compliance for key personnel changes, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: The Foundation failed to notify the Department of Defense about key personnel changes that exceeded 25% of their approved effort, violating NIH and DOD criteria.
  • Recommended Follow-Up: Ensure timely communication of personnel changes to the sponsor and provide additional training to improve adherence to internal controls.

Finding Text

Finding 2022-002 Significant deficiency in internal control over compliance for special tests and provisions. Federal Agency: Department of Defense Pass-Through: N/A Assistance Listing Number: 12.750 Assistance Listing Name: Uniformed Services University Medical Research Projects Award Number: HU00011920056, HU00011920022, HU00011920070 Period of Award: 10/1/19 - 9/30/23, 8/17/18 - 9/30/22, 9/16/19 - 9/15/23 Criteria The National Institutes of Health and the Department of Defense require prior approval for a significant change in the status of key personnel including but not limited to withdrawal from the project; absence for any continuous period of 3 months or more; reduction of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award. Condition/Context The Foundation?s internal controls require management to obtain prior approval for any significant changes or shortfalls of 25 percent or more of stated level of efforts in key personnel, to the award sponsor. During our testing, out of 19 grants tested, we noted 3 grants with instances where individuals identified as key personnel in the agreement either left the Foundation or had over 25% shortfall of level of efforts, and the sponsor was not timely notified. Our sample was not a statistical sample. Cause The Foundation?s internal controls related to notifying the sponsor of changes in key personnel was not consistently applied. Effect or Potential Effect Deficiencies in internal controls related to key personnel could result in material noncompliance. Questioned Costs None. Repeat Finding This is not a repeat finding. Recommendation We recommend changes in key personnel be communicated to the award sponsor prior to the change or as soon as practically possible. We also recommend additional training and/or monitoring to ensure the Foundation?s controls related to notifying the sponsor of changes in key personnel are consistently applied. Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Categories

Special Tests & Provisions Subrecipient Monitoring Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 47375 2022-002
    Significant Deficiency
  • 47376 2022-002
    Significant Deficiency
  • 47377 2022-002
    Significant Deficiency
  • 623818 2022-002
    Significant Deficiency
  • 623819 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
12.420 Military Medical Research and Development $644,108
93.RD Department of Health and Human Services Contracts $589,770
12.351 Basic Scientific Research - Combating Weapons of Mass Destruction $299,248
12.800 Air Force Defense Research Sciences Program $272,197
93.213 Research and Training in Complementary and Integrative Health $243,303
12.431 Basic Scientific Research $209,326
93.855 Allergy and Infectious Diseases Research $166,497
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $126,430
93.865 Child Health and Human Development Extramural Research $91,511
93.279 Drug Abuse and Addiction Research Programs $46,346
12.300 Basic and Applied Scientific Research $41,932
93.837 Cardiovascular Diseases Research $31,810
12.RD Department of Defense Contracts $18,034
12.750 Uniformed Services University Medical Research Projects $8,717
93.395 Cancer Treatment Research $1,502