Thomas Jefferson UniversityNon-Profit

Grantor(s): Health Resources and Services Administration Program: COVID-19 Provider Relief Fund (PRF) Assistance Listing#: 93.498 Title: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Year: 7/2022 – 6/2023 Award #: N/A Pass-through Number: N/A Criteria As specified in the Provider Relief Fund Distributions and American Rescue Plan Rural Distribution Post-Payment Notice of Reporting Requirements, issued on June 11, 2o21 and updated on October 27, 2022 and April 7. 2023, Provider Relief Fund (PRF) recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report in each applicable Reporting Period. Step four requires recipients to report on expenses paid for with payments received (including any interest earned). Expense categories will include general and administrative and/or other health care-related expenses by calendar year quarter. Condition The University reported total general and administrative and other health care-related expenses of $133,333 (for the period January 1, 2021 to June 30, 2021) in the PRF Reporting Portal Submission for Period 3 for the Jefferson University Physicians entity. The University duplicated the reporting of these expenses (for the period July 1, 2021 to December 31, 2021) in the PRF Reporting Portal Submission for Period 4 for the same entity. Cause This finding was due to insufficient review of the report before submission. Effect The duplicate reporting of expenses in the PRF Portal Submission for Period 3 and Period 4 resulted in an incorrect calculation of the “Total Payments Used for Lost Revenues in the Current Reporting Period” section in the “Lost Revenue Summary” section of the PRF Portal Submission for Period 4. The calculated amount of “Total Payments Used for Lost Revenues in the Current Reporting Period” for Period 4 was calculated as $3,084,081 whereas the amount would have been $3,217,414 if the expenses had not been duplicated in the Period 4 PRF Portal Submission Reporting for the Jefferson University Physicians entity. Questioned Costs None. Recommendation Management should enhance the control in place to review each line item and ensure agreement to underlying support on the PRF portal prior to submission. Management’s View and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report. Questioned Costs None. Recommendation Management should enhance the control in place to review each line item and ensure agreement to underlying support on the PRF portal prior to submission. Management’s View and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included in this Report.

Grantor(s): Various Program: Research and Development Cluster Assistance Listing#: Various Title: Research and Development Cluster Award Year: 7/2022 – 6/2023 Award #: N/A Pass-through Number: N/A Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that a physical inventory of the 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)). Condition The University performs a physical inventory of equipment at the department level. Within the Research and Development Cluster, there are 18 departments. Of the 18 departments, 5 departments did not perform the physical inventory at least once in the last two-year period (FY23 and FY22). These 5 departments included 25 individual equipment items that totaled $711,698. The remaining population of 13 departments appropriately performed the physical inventory in the last two-year period over the remaining 125 items totaling $2,294,506 as required. Cause The cause of this finding is due to a lapse in control operation to ensure that the required physical inventory of equipment (or other capitalized assets) acquired under Federal awards was performed by the University at least once every two years. Effect The required physical inventory of equipment (or other capitalized assets) acquired under Federal awards was not performed by the University for 5 departments at least once every two years for R&D related equipment. Questioned Costs None. Recommendation Management should enhance the control in place to ensure that all departments with equipment acquired under Federal Awards are performing the physical inventory when it is requested and ensure that all equipment is verified at least once every two years. Management’s View and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included in this report.

Grantor(s): American Rescue Plan Act (ARPA) Program: American Rescue Plan Act 2 of 2022 Assistance Listing#: 21.027 Title: Coronavirus State and Local Fiscal Recovery Funds Award Year: 7/2022 – 6/2023 Award #: N/A Pass-through Number: 4100086662 Criteria The funds received under Act 2 of 2022 are American Rescue Plan Act funds and are specifically for staff recruitment and retention payments. Recipients do not need to wait until they receive the payments to make payments to qualified staff, but they must spend the funds within the required timeframes. Act 2 of 2022 requires recipients to spend retention payments within 90 calendar days and recruitment payments within 180 calendar days of receipt of the funds. Additionally, hospitals and behavioral health providers may not use the money to pay more than one retention or recruitment payment to qualified staff with Act 2 of 2022 funding. Condition The University received the payments from Act 2 of 2022 on April 20, 2022, and therefore had 90 days to spend the retention payments. Of the $15,674,844 of retention payments spent by the University, 26 payments totaling $25,836 were spent after the performance period ended (7/19/2022). Additionally, the University reported more than one retention payment to 34 qualified staff members amounting to $31,530. Cause The cause of this finding is due to insufficient review of the details of retention payments paid with funds received from this program, specifically as it relates to the required 90-day window to make retention payments and the restriction on the quantity of payments to an individual with funds from this program. Effect Retention payments were spent after the performance period's end, and employees received more than one payment, which resulted in the dollar value of federal expenditures reported in the SEFA being overstated by $57,365. Questioned Costs None. Recommendation If the University receives further funding from this program, management should ensure that any future payments from this program are made within the specified timeline and with the appropriate frequency per the program’s requirements. Additionally, management should contact the Pennsylvania Department of Human Services to determine if any required corrective action related to the error of $58,442. Management’s View and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included in this report.

Finding 2023-004 Enrollment Reporting Grantor(s): Department of Education Program: Student Financial Aid Cluster Assistance Listing#(s): Various Title: Student Financial Aid Cluster Award Year: 7/2021 – 6/2022 Award #: N/A Pass-through Number: N/A Criteria Per the OMB Compliance Supplement, institutions are required to certify enrollment, including changes in students’ enrollment status, at a minimum of every 65 days. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition Through testing a sample of 25 students for enrollment reporting of Pell and Direct Loans, we noted 3 students were reported to the NSLDS outside of the required 65-day window. Each of these 3 students were reported 66 days after their status change. Additionally, for 3 other students in our sample of 25, there was no evidence to support their “graduated” status or date of the status change within the NSLDS. Cause The cause of the delay in reporting to the NSLDS for the first 3 students mentioned above is due to timing with graduation and resource constraints at the University during fiscal year 2022. For the second 3 students, the cause was due to the fact that these students had multiple status changes in a small period of time. The students were “full-time” until 12/31/2021 when they graduated the undergraduate program, then began the graduate program as full-time students in February 2022. The quick change in status was the cause of the NSLDS enrollment status not being supported for these students during fiscal year 2022. Effect NSLDS was not updated timely for the first 3 students mentioned above. For the second 3 students, their enrollment status could potentially be inaccurate in the NSLDS system if their graduation was not processed. Questioned Costs None. Recommendation Management should enhance their resources within the office of the registrar to be able to accommodate status changes during the graduation period and ensure timely status change submission to the NSLDS. Management’s View and Corrective Action Plan Management’s