CONNECTICUT CHILDREN'S MEDICAL CENTER AND SUBSIDIARIESNon-Profit

Agency: U.S. Department of Health and Human Services, U.S. Department of Defense, and U.S. Department of the Treasury, Federal Assistance Listing Number: Various under Research and Development cluster; 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Year: 2024 Pass-Through Entity: University of Vermont, Boston Children’s Hospital, University of North Carolina, Boston Children’s Hospital, University of Connecticut Health Center, Duke University, Redeemer’s University, Oregon Health & Science University, University of Connecticut - Storrs, University of Connecticut Health Center, Public Health Institute, Baylor College of Medicine, Rutgers University, Cincinnati Children’s Hospital Medical Center, Children’s Hospital of Los Angeles, Seattle Children’s, State of Connecticut Judicial Branch, City of Hartford, State of Connecticut Department of Public Health, State of Connecticut Department of Social Services, State of Connecticut Department of Mental Health and Addiction Services Criteria: In accordance with 2 CFR §200.430(i) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), compensation for personal services charged to federal awards must be based on records that accurately reflect the work performed. When budget estimates are used for interim accounting purposes, they must: produce reasonable approximations of the activity actually performed, be reconciled to actual effort on a regular basis, and be adjusted in a timely manner to reflect significant changes in work activity. Documentation may include timesheets, effort certifications, payroll distribution reports, and other personnel activity records, and must be reviewed and approved by authorized personnel. Condition and Context: The Medical Center did not maintain formal documentation evidencing a hindsight review of employee working hours to verify alignment between actual hours worked and budgeted hours. While a time and effort reporting was lacking for the items included in our sample, there was evidence of work performed on the grants and the amounts allocated aligned closely to the budget. Questioned Costs: We were unable to quantify an amount of questioned costs. While a time and effort reporting was lacking for the items included in our sample, there was evidence of work performed on the grants and the amounts allocated aligned closely to the budget. Therefore, we were unable to quantify the amount of questioned costs. Cause: The Medical Center changed its procedures for documenting employee time allocations; however, formal processes were not established to document and regularly reconcile actual hours worked to budgeted allocations. As a result, hindsight reviews were not formally maintained to verify that payroll allocations were supported by employees’ actual work performed. Effect: The lack of documentation of hindsight review increases the risk of inaccurate payroll cost allocations and potential noncompliance with federal grant requirements. Recommendation: The Medical Center should update its policies and procedures to require and document a formal hindsight review of employee working hours. This review should verify that actual hours worked align with budgeted hours, particularly in cases where payroll costs are allocated across multiple grants. The updated procedures should include clear guidelines for conducting and retaining evidence of such reviews to support accurate cost allocations and ensure compliance with federal grant requirements.

Agency: Department of Public Health Federal Assistance Listing Number: 93.268 Immunization Cooperative Agreements Award Year: 2024 Pass-Through Entity: N/A Criteria: In accordance with 42 USC 1396s, effective control and accountability must be maintained for all vaccine administered under the Vaccines for Children (VFC) program. Vaccine inventories must be adequately safeguarded and used solely for authorized purposes, including administration only to eligible children as defined under 42 USC 1396s(b)(2)(A)(i) through (A)(iv). In addition, providers are expected to maintain adequate internal controls over vaccine inventory management and reporting processes, including independent review and approval procedures to ensure the accuracy, completeness, and accountability of vaccine inventory reconciliations and related reporting. Condition and Context: The Medical Center did not have formal policies or procedures in place requiring independent review or approval of vaccine inventory reconciliations. As a result, there was no documented evidence that vaccine inventory balances and doses administered were independently reviewed or verified for accuracy. Questioned Costs: None reported. Cause: The finding was caused by the Medical Center’s lack of established internal control procedures over vaccine inventory records. Specifically, formal review and approval controls, including appropriate segregation of duties, were not implemented to ensure vaccine inventory records were independently verified. Effect: Without independent review and appropriate segregation of duties, the risk increases that errors, omissions, or inaccuracies in vaccine inventory counts may not be detected in a timely manner. This may result in inaccurate vaccine inventory records and noncompliance with program requirements. Recommendation: We recommend that the Medical Center establish and implement formal written policies and procedures requiring timely reconciliation, independent review, and documented approval of vaccine inventory records. The Medical Center should also strengthen segregation of duties by assigning inventory counting, reconciliation preparation, and review responsibilities to different individuals, where feasible, to ensure vaccine inventory information is accurate and complete.