DANA-FARBER CANCER INSTITUTE, INC.Non-Profit

2022-001: Accuracy of PRF Reporting Grantor: Department of Health and Human Services Program Name: Provider Relief Fund Federal Award Year: October 1, 2021 through September 30, 2022 Federal Award Number: Not available Assistance Listing Number: 93.498 Criteria or Requirement PRF recipients that received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report on several required data elements as part of the post-payment reporting process. Reporting must be completed and submitted to HRSA by the reporting dates specified by HRSA. Additionally, Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section 03(a) states the non-Federal entity must 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 Found, Including Perspective The dollar amount of expenses reported by management in the Health Resources and Services Administration (HRSA) portal Period 2 submission ($5,947,568) was incorrect. Management entered the total dollar amounts of expenses for Periods 1 and 2 rather than just the Period 2 expenses that should have been reported in the Period 2 submission. Period 2 expenses should have been $884,911. Possible Cause The condition found results from a misinterpretation of the PRF Reporting Period 2 submission. In completing the PRF Reporting Period 2, the HRSA website automatically populated certain PRF Reporting Period 1 data into the HRSA Reporting Period 2 portal. Management interpreted this to mean that unreimbursed COVID expenses are to be reported on a cumulative basis in the PRF Reporting Period 2 and therefore overstated unreimbursed expenses for Period 1. Effect Failure to ensure accuracy of amounts reported in the portal may result in HRSA relying on incomplete or inaccurate information associated to the Institute?s utilization of PRF funds. Questioned Costs None Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding from the Prior Year No. Recommendation We recommend the Institute enhance its internal controls over PRF reporting to ensure each of the data elements reported to HRSA are accurate and result in amounts consistent with its underlying records. Views of Responsible Officials There was an error in PRF Reporting Period 2 due to a misinterpretation of the instructions, which resulted in the double counting of Period 1 expenses. When it was determined there was an error, the Institute immediately contacted HRSA to request re-opening of the Period 2 report to revise the reported expenses. HRSA did not allow for the re-opening of the reporting period and maintained that the adjustment should be submitted during the Institute?s next reporting period. The Institute will make the adjustment in its next reporting period, Period 5, due by September 2023. The adjustment will net down Period 1 expenses and remedy the double counting issue. As the correct interpretation of the instructions is now known to the Institute, the expenses will be reported to HRSA accurately and consistent with the Institute records moving forward.

(3) Findings and Questioned Costs Relating to Federal Awards 2019-001 Completeness of Equipment Inventory (3) Findings and Questioned Costs Relating to Federal Awards 2019-001 Completeness of Equipment Inventory Research and Development Cluster Grantor: Department of Health and Human Services/National Institutes of Health Program Name: Research and Development Cluster Federal Award Year: October 1, 2018 through September 30, 2019 Federal Award Numbers: See accompanying Schedule of Expenditures of Federal Awards CFDA Numbers: See accompanying Schedule of Expenditures of Federal Awards Criteria or Requirement A physical inventory of property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Further, records for real property and equipment acquired with Federal funds must be retained for three years after final disposition (2 CFR section 200.333(c)). Condition Found, Including Perspective The Institute?s current inventory process control encompasses only equipment acquired with Federal funds during the last five years. Based on the engagement team?s inventory testing, the Institute maintains equipment acquired with Federal funds beyond five years that has not been subjected to the inventory process. Possible Cause The Institute?s general record retention policy is inconsistent with Federal regulations (2 CFR section 200.333(c)). Additionally, there is currently no formal written policy related to the periodic inventorying of equipment acquired with Federal funds. Effect The Institute?s inventory of equipment acquired with Federal funds is incomplete Questioned Costs None identified. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding from the Prior Year No. Recommendation We recommend that the Institute (1) perform a complete inventory count of equipment acquired with Federal funds as required by 2 CFR section 200.313(d)(2) and (2) develop and implement formal written policies related to the periodic inventory of equipment acquired with Federal funds and Federal record retention policies as required by 2 CFR section 200.333(c). Views of Responsible Officials Management agrees with the recommendations to conduct a complete inventory count of equipment acquired with Federal funds, including equipment acquired beyond five years, and to develop separate formal written policies and procedures that are specific to the periodic inventory of equipment acquired with Federal funds. A full inventory of current Federal assets will be performed and verified against the Institute?s Asset Management System. During the inventory the following steps will be taken: a. Verification that all equipment is tagged and on active status. b. Equipment identified as Federal assets that are not tagged will be tagged. c. Untagged assets that are not useable in accordance with Federal regulation (2 CFR section 200.333(c)) will be disposed. d. Records will be retained for three years after final disposition for assets acquired with Federal funds, (2 CFR section 200.333(c)). e. Asset Management tracking modules and reports will be updated to reflect any appropriate changes in the Institute?s records. Once the inventory has been completed all Asset Management personnel and the Research community responsible for equipment management at the Institute will be educated on the federal requirements for record retention of equipment acquired with Federal funds and the updated policies and procedures.

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