Finding Text
Finding 2023-003 – Internal Control Deficiency Over Activities
Allowed/Allowable Costs and Reporting
Identification of the federal program: Federal Grantor: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA)
Assistance Listing No.: Provider Relief Fund and American Rescue Plan (ARP) Rural Distributions
Award Period of Performance: January 1, 2020–June 30, 2023
Criteria or Specific Requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).
Condition: Per discussion with management, OU Medicine, Inc. has processes and internal controls in place to comply with the terms and conditions of the award and the reporting requirements. However, management did not retain documentation evidencing the performance of these controls.
Cause: OU Medicine, Inc. did not consistently retain documentation to evidence the performance of internal controls demonstrating it could comply with the terms and conditions and reporting requirements of the federal program.
Effect or potential effect: Documentation is not complete to support the performance of internal controls.
Questioned Costs: $0
Context: Management did not retain evidence demonstrating the controls for accepting the terms and conditions of the award and reporting.
Identification as a repeat finding, if applicable: The finding is not a repeat finding.
Recommendation: OU Medicine, Inc. should refine its process and retain documentation evidencing that controls were in place to ensure compliance with grant requirements.
View of Responsible Officials: OU Medicine, Inc. agrees with the finding; however, the program has ended. Should OU Medicine, Inc. receive funding in the future, management will implement procedures to ensure documentation of executing the controls is retained.