EIN: 231352685
UEI: GM1XX56LEP58
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 8, 2023. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 8, 2024 (805 days ago).
What is a management decision? →2023-001 Eligibility Federal Grantor: Department of Health and Human Services, Health Resources and Services Administration (“HRSA”) Pass-through Entity: City of Philadelphia, AIDS Activity Coordinating Office (“AACO”) Assistance Listing Title: HIV Emergency Relief Project Grants – Outpatient/Ambulatory Medical Care Assistance Listing Number: 93.914 Award Year: 2023 Award Number: RW2965 Pass-through Number: 2120575-01 Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, “The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.” Additionally, the form states that copy of all documentation are to be retained by the provider. The City of Philadelphia Subrecipient Audit Guide Section 6130.04 provides a list of documents to be maintained and states “case management service providers are required to keep a file on each client served.” Further, per the Universal Monitoring Standards set forth by HRSA, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents. Condition We reviewed a sample of 65 program participants to verify eligibility during the fiscal year. Of the 65 selected, there were 6 program participants at the Wood Clinic within the Clinical Care Associates of the University of Pennsylvania Health System (“Health System”) in which the Health System did not maintain Ryan White certification cards as documentation evidencing the control in place to certify the verification of the program participant’s eligibility. However, for all 6 program participants, the Health System provided records to support that the program participant met the eligibility requirements. Cause Management of the Health System noted that the AACO program at the Wood Clinic ended in November 2022 and the individuals involved in the process did not maintain the documentation evidencing that management verified participant eligibility in the program. Effect Program participants accepted into the program may be ineligible and the Health System may not be able to demonstrate eligibility of the participants. Questioned Costs None Recommendation The Health System should ensure that all individuals involved in the Ryan White certification process are educated that documentation is required to be maintained to support verification of program participant eligibility. Management’s View and Corrective Action Plan Management’s view and corrective action plan is included at the end of this report.
Show full finding ▾Hide full finding ▴2023-001 Eligibility Federal Grantor: Department of Health and Human Services, Health Resources and Services Administration (“HRSA”) Pass-through Entity: City of Philadelphia, AIDS Activity Coordinating Office (“AACO”) Assistance Listing Title: HIV Emergency Relief Project Grants – Outpatient/Ambulatory Medical Care Assistance Listing Number: 93.914 Award Year: 2023 Award Number: RW2965 Pass-through Number: 2120575-01 Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, “The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.” Additionally, the form states that copy of all documentation are to be retained by the provider. The City of Philadelphia Subrecipient Audit Guide Section 6130.04 provides a list of documents to be maintained and states “case management service providers are required to keep a file on each client served.” Further, per the Universal Monitoring Standards set forth by HRSA, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents. Condition We reviewed a sample of 65 program participants to verify eligibility during the fiscal year. Of the 65 selected, there were 6 program participants at the Wood Clinic within the Clinical Care Associates of the University of Pennsylvania Health System (“Health System”) in which the Health System did not maintain Ryan White certification cards as documentation evidencing the control in place to certify the verification of the program participant’s eligibility. However, for all 6 program participants, the Health System provided records to support that the program participant met the eligibility requirements. Cause Management of the Health System noted that the AACO program at the Wood Clinic ended in November 2022 and the individuals involved in the process did not maintain the documentation evidencing that management verified participant eligibility in the program. Effect Program participants accepted into the program may be ineligible and the Health System may not be able to demonstrate eligibility of the participants. Questioned Costs None Recommendation The Health System should ensure that all individuals involved in the Ryan White certification process are educated that documentation is required to be maintained to support verification of program participant eligibility. Management’s View and Corrective Action Plan Management’s view and corrective action plan is included at the end of this report.
While this finding is isolated to the Wood Clinic which ended its AACO program in November 2022, we have communicated the requirement to maintain supporting award documentation to all Penn Medicine practices continuing with Ryan White programs.
2023-002 Procurement, Suspension and Debarment Federal Grantor: Department of Health and Human Services and Department of Defense Program: Research and Development Cluster Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development Assistance Listing Number: 93.853, 12.420 Award Year: 7/1/2022 - 6/30/2023 Award Number: 1-DP2-NS-111996-01, W81XWH2010901 Pass-through Entity: Not applicable Pass-through Number: Not applicable Criteria Per 2 CFR section 180.220, non-federal entities are prohibited from contracting with or making subawards under covered transactions, where vendor purchases exceed $25,000, to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the vendor is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the Vendor, or (3) adding a clause or condition to the covered transaction with that Vendor. University’s policies mirror the procurement policies as required by the Federal government, and defines a covered transaction as purchases exceeding $10,000. Condition In testing compliance with the suspension and debarment compliance requirement, 2 instances of 25 samples selected for testing were noted where the only evidence available to support the date of the performance of the required suspension and debarment checks was after the transaction date, as shown in the chart below. This is a repeat of prior year finding 2022-002. [table] Cause There are no questioned costs associated with this finding.The University uses Visual Compliance (VC) for suspension and debarment checks, which was implemented in 2019. Vendors onboarded prior to the implementation were registered and checked via a separate manual process within the procurement department. The above vendors were on-boarded and checked prior to the VC implementation; however, management could not provide evidence that the vendor check was performed prior to conducting business with the vendor due to the manual nature of the legacy process. Management has subsequently performed checks on these vendors and retained documentation of the checks to validate that the vendors are not currently suspended or debarred. Effect If procedures related to vendor suspended and debarred checks are not performed timely, there is a risk that the purchases could be made with a suspended or debarred vendor. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University continue to follow its corrective action plan. Management’s View and Corrective Action Plan Management’s view and corrective action plan is included at the end of this report.
Show full finding ▾Hide full finding ▴2023-002 Procurement, Suspension and Debarment Federal Grantor: Department of Health and Human Services and Department of Defense Program: Research and Development Cluster Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders; Military Medical Research and Development Assistance Listing Number: 93.853, 12.420 Award Year: 7/1/2022 - 6/30/2023 Award Number: 1-DP2-NS-111996-01, W81XWH2010901 Pass-through Entity: Not applicable Pass-through Number: Not applicable Criteria Per 2 CFR section 180.220, non-federal entities are prohibited from contracting with or making subawards under covered transactions, where vendor purchases exceed $25,000, to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the vendor is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the Vendor, or (3) adding a clause or condition to the covered transaction with that Vendor. University’s policies mirror the procurement policies as required by the Federal government, and defines a covered transaction as purchases exceeding $10,000. Condition In testing compliance with the suspension and debarment compliance requirement, 2 instances of 25 samples selected for testing were noted where the only evidence available to support the date of the performance of the required suspension and debarment checks was after the transaction date, as shown in the chart below. This is a repeat of prior year finding 2022-002. [table] Cause There are no questioned costs associated with this finding.The University uses Visual Compliance (VC) for suspension and debarment checks, which was implemented in 2019. Vendors onboarded prior to the implementation were registered and checked via a separate manual process within the procurement department. The above vendors were on-boarded and checked prior to the VC implementation; however, management could not provide evidence that the vendor check was performed prior to conducting business with the vendor due to the manual nature of the legacy process. Management has subsequently performed checks on these vendors and retained documentation of the checks to validate that the vendors are not currently suspended or debarred. Effect If procedures related to vendor suspended and debarred checks are not performed timely, there is a risk that the purchases could be made with a suspended or debarred vendor. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University continue to follow its corrective action plan. Management’s View and Corrective Action Plan Management’s view and corrective action plan is included at the end of this report.
The University uses the Visual Compliance tool to provide dynamic screening of vendors in order to reduce administrative burden, eliminating the need to run screenings periodically, and to provide timely notification of any potential suspension and debarment issues with vendors. As part of the FY22 audit, we realized that during the transition from manual screening of vendors to the integration of Visual Compliance with our vendor system, the initial screening in Visual Compliance for certain vendors, appeared to have been missed. Therefore, in February 2023, the Procurement Office ran a batch screen on all active vendors missing the screening documentation in VC at that time; and no further action is needed as a result of the current finding. However, due to the timing of that corrective action plan, the 2 vendors, BMG Labtech Inc and Diagnostic Biochips Inc, had invoices paid in FY23 prior to the corrective action such that there was no evidence of their screening in our system at the time of payment.
2022-002
FAC accepted this audit on March 19, 2023 — management decision was due September 19, 2023.
Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Seven instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table This is a repeat of finding 2021-001, 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. For FY22, we note that the overall number of exceptions has decreased. Furthermore, the payments identified as exceptions in the FY22 audit were almost all made to vendors within our institutional standard terms of net 45 days, with the exception of 1 which was made 51 days after the request for reimbursement. The Office of Research Services remains committed to ensuring that the federal government is not unfairly disadvantaged by our processes. To that end, during the fall of 2022, the University implemented certain enhancements to further minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. A custom process was implemented in the University?s financial system to update payment terms to `immediate? for vendor invoices on Line of Credit sponsored awards. In addition, the University added a new metric to the reporting dashboard for its Procure-to-Pay system to specifically highlight Purchase Order invoices for sponsored awards which were on hold, to assist the university business and grant managers in prioritizing the resolution of those holds preventing 2 invoices on sponsored awards from being paid immediately. We expect to see the impact of these enhancements in the FY23 audit.
2021-001
Criteria Per 2 CFR section 180.220, non-federal entities are prohibited from contracting with or making subawards under covered transactions, where vendor purchases exceed $25,000, to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the vendor is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the Vendor, or (3) adding a clause or condition to the covered transaction with that Vendor. University?s policies mirror the procurement policies as required by the Federal government, and defines a covered transaction as purchases exceeding $10,000. Condition In testing compliance with the suspension and debarment compliance requirement, 1 instance of 25 samples selected for testing was noted where the only evidence available to support the date of the performance of the required suspension and debarment checks was after the transaction date, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table Cause The University uses Visual Compliance (VC) for suspension and debarment checks, which was implemented in 2019. Vendors onboarded prior to the implementation were registered and checked via a separate manual process within the procurement department. The above vendor was on-boarded and checked prior to the VC implementation; however, management could not provide evidence that a vendor check was performed prior to conducting business with the vendor due to the manual nature of the legacy process. Management has subsequently performed checks on this vendor and retained documentation of the checks to validate that the vendor is not currently suspended or debarred. Effect If procedures related to vendor suspended and debarred checks are not performed timely, there is a risk that the purchases could be made with a suspended or debarred vendor. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University further enhance related documentation procedures for evaluating suspended or debarred vendors. Prior to making payments to a vendor, the University should document the review of the vendor to ensure checks are performed timely with proper documentation to evidence the outcome of the vendor review process. Views of responsible officials and planned corrective actions Following this finding is Management?s View and Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria Per 2 CFR section 180.220, non-federal entities are prohibited from contracting with or making subawards under covered transactions, where vendor purchases exceed $25,000, to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the vendor is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the Vendor, or (3) adding a clause or condition to the covered transaction with that Vendor. University?s policies mirror the procurement policies as required by the Federal government, and defines a covered transaction as purchases exceeding $10,000. Condition In testing compliance with the suspension and debarment compliance requirement, 1 instance of 25 samples selected for testing was noted where the only evidence available to support the date of the performance of the required suspension and debarment checks was after the transaction date, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table Cause The University uses Visual Compliance (VC) for suspension and debarment checks, which was implemented in 2019. Vendors onboarded prior to the implementation were registered and checked via a separate manual process within the procurement department. The above vendor was on-boarded and checked prior to the VC implementation; however, management could not provide evidence that a vendor check was performed prior to conducting business with the vendor due to the manual nature of the legacy process. Management has subsequently performed checks on this vendor and retained documentation of the checks to validate that the vendor is not currently suspended or debarred. Effect If procedures related to vendor suspended and debarred checks are not performed timely, there is a risk that the purchases could be made with a suspended or debarred vendor. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend the University further enhance related documentation procedures for evaluating suspended or debarred vendors. Prior to making payments to a vendor, the University should document the review of the vendor to ensure checks are performed timely with proper documentation to evidence the outcome of the vendor review process. Views of responsible officials and planned corrective actions Following this finding is Management?s View and Corrective Action Plan.
The University uses the Visual Compliance tool to provide dynamic screening of vendors in order to reduce administrative burden, eliminating the need to run screenings periodically, and to provide timely notification of any potential suspension and debarment issues with vendors. Unfortunately, during the transition from manual screening of vendors to the integration of Visual Compliance with our vendor system, the initial screening in Visual Compliance for this particular vendor, Lambda Labs, appears to have been missed. As the screening for Lambda Labs in VC was run by the procurement office on 8/10/2022, no further action needs to be taken for that vendor. Additionally, in order to address any other vendors which may have missing screening documentation in VC, the University implemented a two-part plan in February 2023. First, the Associate Director of Procurement Systems & Service Operations ran a batch screen on all active vendors missing the screening documentation in VC. Secondly, the procurement office implemented a change in the vendor management tool to place any future supplier transaction on hold where no VC screening exists in the system and prompts Vendor Management to run the screen.
FAC accepted this audit on March 28, 2022 — management decision was due September 28, 2022.
Finding 2021-001 Cash Management Grantor: Centers for Disease Control and Prevention (CDC); Eunice Kennedy Shriver National Institute of Child Health and Human Development; National Cancer Institute/NIH/DHHS; National Eye Institute/NIH/DHHS; National Heart, Lung, and Blood Institute; National Institute of Allergy and Infectious Diseases/NIH/DHHS; National Institute of Arthritis and Musculoskeletal and Skin Diseases; National Institute of Dental and Craniofacial Research/NIH/DHHS; National Institute of Diabetes and Digestive and Kidney Diseases/NIH/DHHS; National Institute of General Medical Sciences/NIH/DHHS; National Institute of Mental Health/NIH/DHHS; National Institute of Neurological Disorders and Stroke/NIH/DHHS; National Institute on Aging/NIH/DHHS; National Science Foundation; Office of The Director, National Institutes of Health/NIH/DHHS; Department of Education Program: Research and Development Cluster; Trio Cluster Assistance Listing#: 47.041; 93.084; 93.121; 93.242; 93.310; 93.353; 93.395; 93.397; 93.838; 93.846; 93.847; 93.853; 93.855; 93.859; 93.865; 93.866; 93.867; 84.042; 84.044; 84.047 Title: Prevention of Disease, Disability, and Death by Infectious Diseases; Child Health and Human Development Extramural Research; 21st Century Cures Act - Beau Biden Cancer Moonshot; Cancer Treatment Research; COVID-19 - Cancer Centers Support Grants; Cancer Treatment Research; Cancer Centers Support Grants; Vision Research; Division of Lung Diseases; Allergy and Infectious Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Oral Diseases and Disorders Research; Diabetes, Digestive, and Kidney Diseases Extramural Research; Biomedical Research and Research Training; Mental Health Research Grants; Extramural Research Programs in the Neurosciences and Neurological Disorders; Aging Research; Engineering; COVID-19 - Engineering; Trans-NIH Research Support; TRIO - Student Support Services; TRIO - Talent Search; TRIO - Upward Bound Award Year: 07/1/2020 ? 06/30/2021 Award Number: 1933400; 1-R01-AR-076381-01A1; 1-R01-HD-102318-01; 1-R21-NS-112742- 01A1; 1-R37-NS-115439-01A1; 1-U54-CA-244711-01; 1-U54-CK-000485-01; 2- R01-DE-023071-06A1; 5-P01-CA-217805-03; 5-P30-CA-016520-42; 5-R01-AG- 054521-03; 5-R01-AI-091627-11; 5-R01-AI-139102-03; 5-R01-DE-027970-03; 5-R01-DK-106309-04; 5-R01-DK-107667-04; 5-R01-EY-026525-06; 5-R01-EY- 027205-04; 5-R01-GM-085207-11; 5-R01-GM-137425-02; 5-R01-MH-118369- 02; 5-R01-NS-113241-02; 5-R01-NS-114226-02; 5-R37-CA-215436-04; 5-U01- HL-148857-02; 5-U19-NS-110456-02; 5-U54-CA-193417-05; CMMI-1548571; P042A150394-16; 9044A160227; P047A180557; P047M180267; P047V170188; P042A200318 Passthrough number: Not Applicable Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 65 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Thirty-six instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. [See Schedule of Findings and Questioned Costs for table] This is a repeat of finding 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-001 Cash Management Grantor: Centers for Disease Control and Prevention (CDC); Eunice Kennedy Shriver National Institute of Child Health and Human Development; National Cancer Institute/NIH/DHHS; National Eye Institute/NIH/DHHS; National Heart, Lung, and Blood Institute; National Institute of Allergy and Infectious Diseases/NIH/DHHS; National Institute of Arthritis and Musculoskeletal and Skin Diseases; National Institute of Dental and Craniofacial Research/NIH/DHHS; National Institute of Diabetes and Digestive and Kidney Diseases/NIH/DHHS; National Institute of General Medical Sciences/NIH/DHHS; National Institute of Mental Health/NIH/DHHS; National Institute of Neurological Disorders and Stroke/NIH/DHHS; National Institute on Aging/NIH/DHHS; National Science Foundation; Office of The Director, National Institutes of Health/NIH/DHHS; Department of Education Program: Research and Development Cluster; Trio Cluster Assistance Listing#: 47.041; 93.084; 93.121; 93.242; 93.310; 93.353; 93.395; 93.397; 93.838; 93.846; 93.847; 93.853; 93.855; 93.859; 93.865; 93.866; 93.867; 84.042; 84.044; 84.047 Title: Prevention of Disease, Disability, and Death by Infectious Diseases; Child Health and Human Development Extramural Research; 21st Century Cures Act - Beau Biden Cancer Moonshot; Cancer Treatment Research; COVID-19 - Cancer Centers Support Grants; Cancer Treatment Research; Cancer Centers Support Grants; Vision Research; Division of Lung Diseases; Allergy and Infectious Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Oral Diseases and Disorders Research; Diabetes, Digestive, and Kidney Diseases Extramural Research; Biomedical Research and Research Training; Mental Health Research Grants; Extramural Research Programs in the Neurosciences and Neurological Disorders; Aging Research; Engineering; COVID-19 - Engineering; Trans-NIH Research Support; TRIO - Student Support Services; TRIO - Talent Search; TRIO - Upward Bound Award Year: 07/1/2020 ? 06/30/2021 Award Number: 1933400; 1-R01-AR-076381-01A1; 1-R01-HD-102318-01; 1-R21-NS-112742- 01A1; 1-R37-NS-115439-01A1; 1-U54-CA-244711-01; 1-U54-CK-000485-01; 2- R01-DE-023071-06A1; 5-P01-CA-217805-03; 5-P30-CA-016520-42; 5-R01-AG- 054521-03; 5-R01-AI-091627-11; 5-R01-AI-139102-03; 5-R01-DE-027970-03; 5-R01-DK-106309-04; 5-R01-DK-107667-04; 5-R01-EY-026525-06; 5-R01-EY- 027205-04; 5-R01-GM-085207-11; 5-R01-GM-137425-02; 5-R01-MH-118369- 02; 5-R01-NS-113241-02; 5-R01-NS-114226-02; 5-R37-CA-215436-04; 5-U01- HL-148857-02; 5-U19-NS-110456-02; 5-U54-CA-193417-05; CMMI-1548571; P042A150394-16; 9044A160227; P047A180557; P047M180267; P047V170188; P042A200318 Passthrough number: Not Applicable Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 65 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Thirty-six instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. [See Schedule of Findings and Questioned Costs for table] This is a repeat of finding 2020-001, 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs. Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Management View and Corrective Action Plan Finding 2021-001 Cash Management Grantor: Centers for Disease Control and Prevention (CDC); Eunice Kennedy Shriver National Institute of Child Health and Human Development; National Cancer Institute/NIH/DHHS; National Eye Institute/NIH/DHHS; National Heart, Lung, and Blood Institute; National Institute of Allergy and Infectious Diseases/NIH/DHHS; National Institute of Arthritis and Musculoskeletal and Skin Diseases; National Institute of Dental and Craniofacial Research/NIH/DHHS; National Institute of Diabetes and Digestive and Kidney Diseases/NIH/DHHS; National Institute of General Medical Sciences/NIH/DHHS; National Institute of Mental Health/NIH/DHHS; National Institute of Neurological Disorders and Stroke/NIH/DHHS; National Institute on Aging/NIH/DHHS; National Science Foundation; Office of The Director, National Institutes of Health/NIH/DHHS; Department of Education Program: Research and Development Cluster; Trio Cluster Assistance Listing#: 47.041; 93.084; 93.121; 93.242; 93.310; 93.353; 93.395; 93.397; 93.838; 93.846; 93.847; 93.853; 93.855; 93.859; 93.865; 93.866; 93.867; 84.042; 84.044; 84.047 Title: Prevention of Disease, Disability, and Death by Infectious Diseases; Child Health and Human Development Extramural Research; 21st Century Cures Act - Beau Biden Cancer Moonshot; Cancer Treatment Research; COVID-19 - Cancer Centers Support Grants; Cancer Treatment Research; Cancer Centers Support Grants; Vision Research; Division of Lung Diseases; Allergy and Infectious Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Oral Diseases and Disorders Research; Diabetes, Digestive, and Kidney Diseases Extramural Research; Biomedical Research and Research Training; Mental Health Research Grants; Extramural Research Programs in the Neurosciences and Neurological Disorders; Aging Research; Engineering; COVID-19 - Engineering; Trans-NIH Research Support; TRIO - Student Support Services; TRIO - Talent Search; TRIO - Upward Bound Award Year: 07/1/2020 ? 06/30/2021 Award Number: 1933400; 1-R01-AR-076381-01A1; 1-R01-HD-102318-01; 1-R21-NS-112742- 01A1; 1-R37-NS-115439-01A1; 1-U54-CA-244711-01; 1-U54-CK-000485-01; 2- R01-DE-023071-06A1; 5-P01-CA-217805-03; 5-P30-CA-016520-42; 5-R01-AG- 054521-03; 5-R01-AI-091627-11; 5-R01-AI-139102-03; 5-R01-DE-027970-03; 5-R01-DK-106309-04; 5-R01-DK-107667-04; 5-R01-EY-026525-06; 5-R01-EY- 027205-04; 5-R01-GM-085207-11; 5-R01-GM-137425-02; 5-R01-MH-118369- 02; 5-R01-NS-113241-02; 5-R01-NS-114226-02; 5-R37-CA-215436-04; 5-U01- HL-148857-02; 5-U19-NS-110456-02; 5-U54-CA-193417-05; CMMI-1548571; P042A150394-16; 9044A160227; P047A180557; P047M180267; P047V170188; P042A200318 Passthrough number: Not Applicable The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. For FY21, which is consistent since FY17 when the finding was first identified, we note that these exceptions only relate to payables transactions. Payables account for approximately 20% of costs across all federal awards (the other 80% of costs are payroll and fringe, indirect costs, and other internal billings and journals for which cash management is not an issue). Also, the payments identified as exceptions in the audit were all made to vendors within our institutional standard terms of net 45 days. The Office of Research Services is committed to ensuring that the federal government is not unfairly disadvantaged by our processes. To that end, we are currently exploring several possible process changes to further reduce the time lapse between request for reimbursement from sponsoring agencies and vendor payment or develop a process to mitigate the time lapse effect. Any changes will be decided upon by the end of the current fiscal year. Elizabeth D. Peloso Associate Vice President / Associate Vice Provost Research Services epeloso@upenn.edu 215-898-7293
2020-001
Finding 2021-002 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster Assistance listing#: 84.063, 84.268 Title: Federal Pell Grant, Federal Direct Loans Award Year: 07/1/2020 ? 06/30/2021 Award Number: P063P202158, P063P20192158 Passthrough number: Not Applicable Criteria National Student Loan Data System (NSLDS) Enrollment Reporting Guide 1.1 ? The collection of enrollment data is essential to the Department for many reasons: - It protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data. - It ensures loan repayment dates are accurately based on the last date of attendance. - It allows in-school deferments to be automatically granted using NSLDS enrollment data. - It provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. NSLDS Enrollment Reporting Guide 1.4 ? At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its thirdparty servicer. 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. NSLDS Enrollment Reporting Guide 4.3 ? As noted previously, there are two categories of enrollment information: ?Campus Level? and ?Program-Level?, both of which need to be reported and have separate record types. NSLDS Enrollment Reporting Guide 4.4.3 ? It is important to note that, for a student who has graduated, schools who initially report a withdrawn status must subsequently report the student as having graduated by certifying a `G? status at the Campus-Level and/or Program-Level as appropriate. This is true even if the student or the student?s applicable program no longer appears on the school?s Enrollment Reporting Roster because the school has certified the `W? status twice. In this case, the school must add the student and/or program back to the Roster to report the `G?. The graduated status may protect the interest subsidy on the student?s current loans. Condition Of 25 students selected with changes in enrollment status, two changes in enrollment status were reported to the NSLDS more than 60 days after the student left the University. Additionally, information for 4 students included separation date, campus level, or program level information reported to the thirdparty service provider and NSLDS that did not agree to the student file. The correct enrollment information was sent to the third-party service provider and NSLDS upon discovery of the errors during the audit. [See Schedule of Findings and Questioned Costs for chart/table] Cause The University?s monitoring process over information reported to the third-party service provider and NSLDS did not ensure the information was transferred timely and agreed to student file information, as is required by the criteria cited above. Effect The changes in enrollment status were not reported correctly or timely to the third-party service provider and NSDLS, as required by the criteria cited above. Questioned Costs None. Recommendation Management should enhance their monitoring controls over student enrollment status changes to ensure that enrollment information is accurate and agrees to student files prior to providing to the third-party servicer and NSLDS. These controls should include ensuring the student information system is properly capturing changes to be sent to NSLDS. Additionally, a detailed review of enrollment changes should occur prior to submission to the third-party service provided and NSLDS to ensure accuracy of the information transmitted. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-002 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster Assistance listing#: 84.063, 84.268 Title: Federal Pell Grant, Federal Direct Loans Award Year: 07/1/2020 ? 06/30/2021 Award Number: P063P202158, P063P20192158 Passthrough number: Not Applicable Criteria National Student Loan Data System (NSLDS) Enrollment Reporting Guide 1.1 ? The collection of enrollment data is essential to the Department for many reasons: - It protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data. - It ensures loan repayment dates are accurately based on the last date of attendance. - It allows in-school deferments to be automatically granted using NSLDS enrollment data. - It provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. NSLDS Enrollment Reporting Guide 1.4 ? At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its thirdparty servicer. 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. NSLDS Enrollment Reporting Guide 4.3 ? As noted previously, there are two categories of enrollment information: ?Campus Level? and ?Program-Level?, both of which need to be reported and have separate record types. NSLDS Enrollment Reporting Guide 4.4.3 ? It is important to note that, for a student who has graduated, schools who initially report a withdrawn status must subsequently report the student as having graduated by certifying a `G? status at the Campus-Level and/or Program-Level as appropriate. This is true even if the student or the student?s applicable program no longer appears on the school?s Enrollment Reporting Roster because the school has certified the `W? status twice. In this case, the school must add the student and/or program back to the Roster to report the `G?. The graduated status may protect the interest subsidy on the student?s current loans. Condition Of 25 students selected with changes in enrollment status, two changes in enrollment status were reported to the NSLDS more than 60 days after the student left the University. Additionally, information for 4 students included separation date, campus level, or program level information reported to the thirdparty service provider and NSLDS that did not agree to the student file. The correct enrollment information was sent to the third-party service provider and NSLDS upon discovery of the errors during the audit. [See Schedule of Findings and Questioned Costs for chart/table] Cause The University?s monitoring process over information reported to the third-party service provider and NSLDS did not ensure the information was transferred timely and agreed to student file information, as is required by the criteria cited above. Effect The changes in enrollment status were not reported correctly or timely to the third-party service provider and NSDLS, as required by the criteria cited above. Questioned Costs None. Recommendation Management should enhance their monitoring controls over student enrollment status changes to ensure that enrollment information is accurate and agrees to student files prior to providing to the third-party servicer and NSLDS. These controls should include ensuring the student information system is properly capturing changes to be sent to NSLDS. Additionally, a detailed review of enrollment changes should occur prior to submission to the third-party service provided and NSLDS to ensure accuracy of the information transmitted. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Management View and Corrective Action Plan Finding 2021-002 Enrollment Reporting Grantor: Department of Education Program: Student Financial Assistance Cluster Assistance listing#: Title: 84.063, 84.268 Federal Pell Grant, Federal Direct Loans Award Year: 07/1/2020 ? 06/30/2021 Award Number: P063P202158, P063P20192158 Passthrough Number: Not Applicable Student Registration and Financial Services (SRFS) Management will enhance their monitoring controls over student enrollment status changes to ensure that enrollment information is accurate and agrees to student files prior to providing to the National Student Clearinghouse (NSC) (third-party servicer) and NSLDS. We are implementing a new Student Information System. The new system will properly capture changes to be sent to NSLDS. Additionally, a detailed review of enrollment changes will take place prior to submission to the NSC (third-party servicer) and NSLDS to ensure accuracy of the information transmitted. Matthew D. Sessa Executive Director, Student Registration and Financial Services msessa@upenn.
2021-003 Eligibility Grantor: Department of Health and Human Services, Pass-through City of Philadelphia, AIDS Activity Coordinating Office (AACO) Program: Ryan White HIV/AIDS Title: HIV Emergency Relief Project Grants Assistance Listing #: 93.914 Award Year: 2020-2021, 2021-2022 Award Number: 1720666-03 (RW0968, RW0866, RS0944); 2120578 (RS1944, RW1968, RW1866) Passthrough number: Not Applicable Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, ?The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.? Additionally, the form states copies of all documentation are to be retained by the Provider. The City of Philadelphia Audit Guide section 6130.04 provides a list of documents to be maintained and states ?case management service providers are required to keep a file on each client served.? Additionally, per the Universal Monitoring Standards set forth by the Health Resources and Services Administration (HRSA) of the Department of Health and Human Services, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify their eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents. Condition Health Resources and Services Administration of the Department of Health and Human Services standards require service providers who receive Ryan White funding to screen clients and collect documentation to support the patient?s eligibility for Ryan White funded services, including but not limited to an HIV positive diagnosis, identity, residency, insurance status, and income level. These requirements were sent to the University of Pennsylvania (?the University?) by the City of Philadelphia as part of its contract to provide services. For the AACO Medical awards, 3 out of a sample of 60 patient files selected for eligibility testing did not contain sufficient evidence of income level to support the Provider?s eligibility determination. Cause Management retains income support for patients visiting the clinic that apply for financial assistance to cover the cost of their visit. However, the clinic also serves HIV positive patients that have their own private insurance and do not request financial assistance. For 3 samples selected for eligibility testing, management was unable to provide income support for the patients selected as all the patients were determined to be covered by private insurance. Management provided records to support the other eligibility requirements, including the HIV positive diagnosis of the patient, but was unable to provide income support relating to the eligibility requirement. Effect Patient care may be provided to ineligible patients. Questioned Costs None, as a form of documentation to support eligibility was ultimately provided for each patient and payment was made through private insurance. Recommendation The University should ensure proper documentation is retained to support all eligibility requirements, including level of income. Management should implement a periodic review control to detect any patients who are missing eligibility documentation and obtain the missing documentation. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴2021-003 Eligibility Grantor: Department of Health and Human Services, Pass-through City of Philadelphia, AIDS Activity Coordinating Office (AACO) Program: Ryan White HIV/AIDS Title: HIV Emergency Relief Project Grants Assistance Listing #: 93.914 Award Year: 2020-2021, 2021-2022 Award Number: 1720666-03 (RW0968, RW0866, RS0944); 2120578 (RS1944, RW1968, RW1866) Passthrough number: Not Applicable Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, ?The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.? Additionally, the form states copies of all documentation are to be retained by the Provider. The City of Philadelphia Audit Guide section 6130.04 provides a list of documents to be maintained and states ?case management service providers are required to keep a file on each client served.? Additionally, per the Universal Monitoring Standards set forth by the Health Resources and Services Administration (HRSA) of the Department of Health and Human Services, the Ryan White HIV/AIDS Program Part A and B Monitoring Standards require service providers who receive Ryan White funding to screen to certify their eligibility for Ryan White-funded services. The guidance states that documentation of eligibility determination is required in client records, as evidenced by copies of documents. Condition Health Resources and Services Administration of the Department of Health and Human Services standards require service providers who receive Ryan White funding to screen clients and collect documentation to support the patient?s eligibility for Ryan White funded services, including but not limited to an HIV positive diagnosis, identity, residency, insurance status, and income level. These requirements were sent to the University of Pennsylvania (?the University?) by the City of Philadelphia as part of its contract to provide services. For the AACO Medical awards, 3 out of a sample of 60 patient files selected for eligibility testing did not contain sufficient evidence of income level to support the Provider?s eligibility determination. Cause Management retains income support for patients visiting the clinic that apply for financial assistance to cover the cost of their visit. However, the clinic also serves HIV positive patients that have their own private insurance and do not request financial assistance. For 3 samples selected for eligibility testing, management was unable to provide income support for the patients selected as all the patients were determined to be covered by private insurance. Management provided records to support the other eligibility requirements, including the HIV positive diagnosis of the patient, but was unable to provide income support relating to the eligibility requirement. Effect Patient care may be provided to ineligible patients. Questioned Costs None, as a form of documentation to support eligibility was ultimately provided for each patient and payment was made through private insurance. Recommendation The University should ensure proper documentation is retained to support all eligibility requirements, including level of income. Management should implement a periodic review control to detect any patients who are missing eligibility documentation and obtain the missing documentation. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Finding 2021-003 Eligibility Grantor: Department of Health and Human Services, Pass-through City of Philadelphia, Aids Activity Coordinating Office (AACO) Program: Ryan White HIV/AIDS Title: HIV Emergency Relief Project Grants Assistance Listing#: 93.914 Award Year: 2020-2021, 2021-2022 Award Number: 1720666-03 (RW0968, RW0866, RS0944); 2120578 (RS1944, RW1968, RW1866) Passthrough Number: Not Applicable The Ryan White clinic at the Penn Presbyterian Medical Center experienced some staff performance issues during FY21 which contributed to some patients not being assessed for RW certification. All of these patients received the medical services needed, and none were denied services despite the lack of assessment. During FY22, a new Financial Counselor was hired to do the RW certifications and the Program Manager discussed the results of the audit with the new Financial Counselor to highlight the previous staff member?s past shortfalls and stress the need for the clinic to certify Ryan White patients in a timely manner. Thomas W. Cooper Vice President UPHS Corporate Finance thomas.cooper@uphs.upenn.edu 267-414-2344
FAC accepted this audit on February 16, 2021 — management decision was due August 16, 2021.
Finding 2020-001 Cash Management Grantor: National Institute of Aging, National Institute of Health (NIH), Department of Health and Human Services (DHHS); National Institute of Diabetes and Digestive and Kidney Diseases, NIH, DHHS; National Center for Advancing Translational Sciences, NIH, DHHS; National Cancer Institute, NIH, DHHS; National Science Foundation; Department of Education Program: Research and Development Cluster; Twenty-First Century Community Learning Centers CFDA#: 93.866; 93.847; 93.350; 93.397; 47.041; 84.287 Title: Coordinating Center for Genetics and Genomics of Alzheimer's Disease (CGAD); Penn integrated Human Pancreas procurement and Analysis Program; Institutional Clinical and Translational Science Award; Abramson Cancer Center Support Grant; Science and Technology Center for Mechano-Biology; Twenty-First Century Community Learning Centers Award Year: 07/1/2019 ? 06/30/2020 Award Number: 1-U54-AG-052427-01; 1-UC4-DK-112217-01; 1-UL1-TR-001879-01; 2-P30-CA-016520-40; CMMI-1548571; 4100068078; FC #4100071658; SUB TO S287C170038 Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Twenty-six instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat of finding 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was request for allowable costs Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-001 Cash Management Grantor: National Institute of Aging, National Institute of Health (NIH), Department of Health and Human Services (DHHS); National Institute of Diabetes and Digestive and Kidney Diseases, NIH, DHHS; National Center for Advancing Translational Sciences, NIH, DHHS; National Cancer Institute, NIH, DHHS; National Science Foundation; Department of Education Program: Research and Development Cluster; Twenty-First Century Community Learning Centers CFDA#: 93.866; 93.847; 93.350; 93.397; 47.041; 84.287 Title: Coordinating Center for Genetics and Genomics of Alzheimer's Disease (CGAD); Penn integrated Human Pancreas procurement and Analysis Program; Institutional Clinical and Translational Science Award; Abramson Cancer Center Support Grant; Science and Technology Center for Mechano-Biology; Twenty-First Century Community Learning Centers Award Year: 07/1/2019 ? 06/30/2020 Award Number: 1-U54-AG-052427-01; 1-UC4-DK-112217-01; 1-UL1-TR-001879-01; 2-P30-CA-016520-40; CMMI-1548571; 4100068078; FC #4100071658; SUB TO S287C170038 Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing compliance with the cash management compliance requirement, specifically the reimbursement-method, 40 individual expenditures were tested to compare the date the University made payment to a vendor for a selected expense transaction to the date the University requested sponsor reimbursement for the same transaction. Twenty-six instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat of finding 2019-001, 2018-002 and 2017-002 in prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was request for allowable costs Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Management View and Corrective Action Plan Finding 2020-001 Cash Management Grantor: National Institute of Aging, National Institute of Health (NIH), Department of Health and Human Services (DHHS); National Institute of Diabetes and Digestive and Kidney Diseases, NIH, DHHS; National Center for Advancing Translational Sciences, NIH, DHHS; National Cancer Institute, NIH, DHHS; National Science Foundation; Department of Education Program: Research and Development Cluster; Twenty-First Century Community Learning Centers CFDA#: 93.866; 93.847; 93.350; 93.397; 47.041; 84.287 Title: Coordinating Center for Genetics and Genomics of Alzheimer's Disease (CGAD); Penn integrated Human Pancreas procurement and Analysis Program; Institutional Clinical and Translational Science Award; Abramson Cancer Center Support Grant; Science and Technology Center for Mechano-Biology; Twenty-First Century Community Learning Centers Award Year: 07/1/2019 ? 06/30/2020 Award Number: 1-U54-AG-052427-01; 1-UC4-DK-112217-01; 1-UL1-TR-001879-01; 2-P30-CA-016520-40; CMMI-1548571; 4100068078; FC #4100071658; S287C170038 The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. If there is no resolution by OMB or change to the requirement in the Compliance Supplement we will work with our cognizant agency to arrive at a solution that fits the interests of all parties. During 2020, the Director of Cost Analysis in the Office of Research Services (ORS) repeatedly contacted PMS/DHHS to discuss a resolution to cash management audit findings from previous years and to obtain a management decision but has yet to receive a response. ORS will continue to seek Management Decision letters from PMS on the cash management findings. Again, for FY20, we note that these only relate to payables transactions. Payables account for approximately 20% of costs across all federal awards (the other 80% of costs are payroll and fringe, indirect costs, and other internal billings and journals for which cash management is not an issue). Also, the payments identified as exceptions in the audit were all made to vendors within our institutional standard terms of net 45 days. Lastly, for the cash management exceptions related to the Twenty-First Century Community Learning Centers program, we note that although the University of Pennsylvania requested reimbursement from the non-federal prime sponsor prior to issuing payment on the vendor invoices, we received the reimbursements well after the vendor invoices were paid.
2019-001
FAC accepted this audit on January 8, 2020 — management decision was due July 8, 2020.
Finding 2019-001 Cash Management Grantor: National Science Foundation (NSF), Directorate for Biological Sciences; Department of Health and Human Services (DHHS), National Institute of Health (NIH), National Center for Advancing Translational Sciences; DHHS, NIH, National Institute on Minority Health and Health Disparities; DHHS, NIH, National Institute on Aging; DHHS, NIH, National Cancer Institute DHHS, NIH, National Institute of Allergy and Infectious Diseases Program: Research and Development Cluster CFDA#: 47.041, 93.350, 93.307, 93.866, 93.397, 93.855 Title: Science and Technology Center for Mechano-Biology; Institutional Clinical and Translational Science Award; Reducing HIV vulnerability through a multilevel life skills intervention for adolescent men; Epigenetics of Aging and Age-Associated Diseases; Alzheimer's Disease Genetics Consortium; Abramson Cancer Center Support Grant; Targeting Blys/Baff in Non-Human Primate Islet Transplantation Award Year: 07/1/2018 ? 06/30/2019 Award Number: CMMI-1548571; 5-UL1-TR-001878-03; 5-U01-MD-011274-03; 2-P01-AG-031862-12; 5-U01-AG-032984-09; 5-P30-CA-016520-42; 4-U01-AI-102430-05 Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing conformity with the cash management reimbursement-method, 40 individual expenditures were tested to compare the date of University payment to the vendor to the date of request for reimbursement from the Government to the University. Eighteen instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. [See Schedule of Findings and Questioned Costs for chart/table] This is a repeat of finding 2018-002 and 2017-002 in the prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-001 Cash Management Grantor: National Science Foundation (NSF), Directorate for Biological Sciences; Department of Health and Human Services (DHHS), National Institute of Health (NIH), National Center for Advancing Translational Sciences; DHHS, NIH, National Institute on Minority Health and Health Disparities; DHHS, NIH, National Institute on Aging; DHHS, NIH, National Cancer Institute DHHS, NIH, National Institute of Allergy and Infectious Diseases Program: Research and Development Cluster CFDA#: 47.041, 93.350, 93.307, 93.866, 93.397, 93.855 Title: Science and Technology Center for Mechano-Biology; Institutional Clinical and Translational Science Award; Reducing HIV vulnerability through a multilevel life skills intervention for adolescent men; Epigenetics of Aging and Age-Associated Diseases; Alzheimer's Disease Genetics Consortium; Abramson Cancer Center Support Grant; Targeting Blys/Baff in Non-Human Primate Islet Transplantation Award Year: 07/1/2018 ? 06/30/2019 Award Number: CMMI-1548571; 5-UL1-TR-001878-03; 5-U01-MD-011274-03; 2-P01-AG-031862-12; 5-U01-AG-032984-09; 5-P30-CA-016520-42; 4-U01-AI-102430-05 Criteria 2 CFR 200.305 (b3): Reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.207 Specific conditions, or when the non-Federal entity requests payment by reimbursement. Per the OMB Compliance Supplement, the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition In testing conformity with the cash management reimbursement-method, 40 individual expenditures were tested to compare the date of University payment to the vendor to the date of request for reimbursement from the Government to the University. Eighteen instances were noted in which the University paid the vendor after requesting and receiving reimbursement from the government, as shown in the chart below. [See Schedule of Findings and Questioned Costs for chart/table] This is a repeat of finding 2018-002 and 2017-002 in the prior year audit reports. Cause Management?s current process to ensure that the reimbursement of expenditures occurs only after paying the vendor utilizes the assumption that vendors will be paid within 30 days, on average, of incurring the expense. Effect The University received Federal reimbursement prior to paying the vendors for the selected expenses. The reliance of the 30 day average time-frame allowed certain expenditures to be included in requests for reimbursement prior to being liquidated. Questioned Costs None as reimbursement was requested for allowable costs Recommendation The University should revisit existing internal control procedures to ensure expenditures are paid in compliance with the Federal reimbursement requirements. We also recommend management discuss current cash management requirements with the OMB and the University?s cognizant agency to determine a solution that meets the needs of both parties. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. If there is no resolution by OMB or change to the requirement in the Compliance Supplement we will work with our cognizant agency to arrive at a solution that fits the interests of all parties. In addition, the Director of Cost Analysis in the Office of Research Services recently contacted PMS/DHHS on January 3, 2020 to discuss a resolution to cash management audit findings from previous years and to obtain a management decision and will continue to contact PMS over the next year to try and reach a resolution on the cash management finding for this year and previous years. For FY19, although 18 exceptions out of 40 tested selections appear to represent a high percentage, we note that these only relate to payables transactions. Payables account for approximately 20% of costs across all federal awards (the other 80% of costs are payroll and fringe, indirect costs, and other internal billings and journals for which cash management is not an issue). We also note that while cash management was also tested on one other major programs under the FY19 audit, exceptions are only noted in the R&D cluster. Several years ago when awards with our major federal sponsoring agencies were on pooled drawdowns, Penn was able to hold back 20% of each draw down request to help mitigate this payables time-lag issue. This continues to be the case for awards which are still on pooled drawdown. However, when the agencies began to require specific, or itemized, drawdowns, Penn completely reconfigured its sponsored invoicing system. The new requirement made it infeasible to hold back a portion of the new itemized drawdown requests. These 18 noted exceptions are only on awards under the itemized drawdown method of collections. However, in order to help mitigate any unreasonable time lapses between payments to vendors and reimbursement requests from sponsors, Penn made considerable efforts to improve and streamline the payables process, which included paying our vendors on a more timely and automatic basis. Under the Procure-to-Pay initiative, Penn created a supplier portal, allowing our suppliers to register and reduce administrative burdens and delays with Purchase Orders and invoice payments. Those registered suppliers electing to take advantage of Penn?s preferred electronic payment offerings, are able to retain Net 30 terms or better, depending on their payment selection. Those electing to take payment via check are paid in Net 45 days. The initiative was designed to encourage our suppliers/vendors to register and receive the best payment terms possible, thereby minimizing the time between request for reimbursement from sponsoring agencies and vendor payment. This mitigating control and reasonable payment terms are reflected in the Days Variance figures for each exception where most were within 30 days. Regarding the one noted invoice with a variance of 73 days between the date of government reimbursement and the date of payment to the vendor, the PI delayed in approving the subrecipient invoice, which then delayed the department?s approval for invoice payment. ORS will work with the department to discuss an enhancement to their subrecipient monitoring procedures so that if PI approval is delayed in the future, the department will still move the invoice along for timely payment.
Finding 2019-002 Period of Performance Grantor: Department of Health and Human Services, National Institute of Allergy and Infectious Diseases; Department of Health and Human Services, National Institute of Neurological Disorders and Stroke Program: Research and Development Cluster CFDA#: 93.855; 93.853 Title: Targeting Blys/Baff in Non-Human Primate Islet Transplantation; Paraneoplastic Disorders of the CNS: Autoantigen Profiling Award Year: 07/1/2018 ? 06/30/2019 Award Number: 4-U01-AI-102430-05; 5-R01-NS-077851-08 Criteria 2 CFR section 200.309 ? ?A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. 2 CFR section 200.343(b) - Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. NIH Grants Policy Statement ? ?Recipients must submit a final FFR, Final RPPR, and Final Invention Statement and Certification within 120 calendar days of the end of the period of performance (project period.? Condition Twenty-five awards with a period of performance ending within the fiscal year were tested. One award was noted with an expense totaling $1,148 in which the invoice date of 8/27/2018 was after the award period end date of 7/31/2018. The related Department of Health and Human Services award number is 4- U01-AI-102430-05. Additionally, one award was noted with an expense totaling $84,459 in which the University paid the vendor on 1/8/2019, which was 161 days after the award period end date of 7/31/2018. The related Department of Health and Human Services award number is 5-R01-NS-077851- 08. Cause For the first exception, management?s monitoring control did not operate effectively, allowing the approval of the expense to be charged to the Federal award outside the period of the award. For the second exception, the invoice was received by management after award period end but during the 120 day close-out period. Upon receipt, management submitted the invoice for payment, but a delay in initiating a purchase order occurred, which further delayed the payment process. Effect The University incurred the first expenditure on the award outside of the period of performance. Additionally, the University did not liquidate the second expenditure in accordance with the criteria cited above. Questioned Costs $1,148, as only the first expense was considered to be outside of the period of the award. Recommendation Management should further educate the individuals responsible for approving expenditures to ensure they are incurred within the period of the award. Additionally, management should enhance the back-end monitoring/review control to ensure expenditures are within the period of the award. Additionally, as part of the award close-out and financial reporting process, management should enhance the control to ensure liquidation occurs within the appropriate threshold after the award end date. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-002 Period of Performance Grantor: Department of Health and Human Services, National Institute of Allergy and Infectious Diseases; Department of Health and Human Services, National Institute of Neurological Disorders and Stroke Program: Research and Development Cluster CFDA#: 93.855; 93.853 Title: Targeting Blys/Baff in Non-Human Primate Islet Transplantation; Paraneoplastic Disorders of the CNS: Autoantigen Profiling Award Year: 07/1/2018 ? 06/30/2019 Award Number: 4-U01-AI-102430-05; 5-R01-NS-077851-08 Criteria 2 CFR section 200.309 ? ?A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity. 2 CFR section 200.343(b) - Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. NIH Grants Policy Statement ? ?Recipients must submit a final FFR, Final RPPR, and Final Invention Statement and Certification within 120 calendar days of the end of the period of performance (project period.? Condition Twenty-five awards with a period of performance ending within the fiscal year were tested. One award was noted with an expense totaling $1,148 in which the invoice date of 8/27/2018 was after the award period end date of 7/31/2018. The related Department of Health and Human Services award number is 4- U01-AI-102430-05. Additionally, one award was noted with an expense totaling $84,459 in which the University paid the vendor on 1/8/2019, which was 161 days after the award period end date of 7/31/2018. The related Department of Health and Human Services award number is 5-R01-NS-077851- 08. Cause For the first exception, management?s monitoring control did not operate effectively, allowing the approval of the expense to be charged to the Federal award outside the period of the award. For the second exception, the invoice was received by management after award period end but during the 120 day close-out period. Upon receipt, management submitted the invoice for payment, but a delay in initiating a purchase order occurred, which further delayed the payment process. Effect The University incurred the first expenditure on the award outside of the period of performance. Additionally, the University did not liquidate the second expenditure in accordance with the criteria cited above. Questioned Costs $1,148, as only the first expense was considered to be outside of the period of the award. Recommendation Management should further educate the individuals responsible for approving expenditures to ensure they are incurred within the period of the award. Additionally, management should enhance the back-end monitoring/review control to ensure expenditures are within the period of the award. Additionally, as part of the award close-out and financial reporting process, management should enhance the control to ensure liquidation occurs within the appropriate threshold after the award end date. Management?s View and Corrective Action Plan Following these findings are management?s view and corrective action plan.
For the $1,148 questioned cost which was out of the period of the award, the Office of Research Services clarified with the department that the expense to replace disposable surgical instruments which were utilized on the award but not received until after the award period ended is unallowable to the award. The Director of Cost Analysis in the Office of Research Services will work with the department to remove the cost from the award and refund the amount to the sponsor before the end of fiscal year 2020. For the noted exception of the invoice paid 161 days after the award period end date, during its closeout process ORS discovered that the subrecipient had not yet issued an invoice to Penn for the final award year. Once the department obtained the invoice, ORS evaluated the allowability of the cost and determined it as appropriately within the period of performance of the award, thereby accruing it on the final financial report. ORS followed up again with the department during its continued monitoring procedures as the cost did not materialize in a timely manner, and continued to assist the department and monitor the situation until the expense was recognized on the award ledger and paid. This was an unusual and exceptional situation. One of Penn?s period of performance controls prevents the creation of new purchase orders on awards after the award period end date. Thus the invoice payment was further delayed as the department had to work with ORS and Accounts Payable to work out a non-standard payment process.
Finding 2019-003 is an additional finding included in the report based upon the results of the audit of the University of Pennsylvania?s City of Philadelphia Awards. As this program includes Federal funding, it has also been included within this report. 2019-003 Eligibility Grantor: Department of Health and Human Services, Pass-through City of Philadelphia, AIDS Activity Coordinating Office (AACO) Program: Ryan White HIV/AIDS Title: HIV Emergency Relief Project Grants CFDA: 93.914 Award Year: 2018-2019, 2019-2020 Award Number: 1720668-01 (RW8668, RW8969); 1720668-02 (RW9668, RW9969) Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, ?The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.? Additionally, the form states copies of all documentation are to be retained by the Provider. The City of Philadelphia Audit Guide section 6130.04 provides a list of documents to be maintained and states ?case management service providers are required to keep a file on each client served.? Additionally, per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, if the client presents an active Special Pharmaceutical Benefits Program (SPBP) card, the client has satisfied the income requirement without need for any additional supporting documentation. A copy of the card should be retained on file and status should be verified for cards without an expiration date. Status can be verified by calling the SPBP program with the number on the card. Condition Health Resources and Services Administration of the Department of Health and Human Services standards require service providers who receive Ryan White funding to screen clients and collect documentation to support the patient?s eligibility for Ryan White funded services, including but not limited to an HIV positive diagnosis, identity, residency, insurance status, and income level. These requirements were sent to the University of Pennsylvania (?the University?) by the City of Philadelphia as part of its contract to provide services. For the AACO Medical awards, 3 of a sample of 60 patient files selected for eligibility testing did not contain sufficient evidence of income level to support the Provider?s eligibility determination. Cause Management retains income support for the most recent eligibility determination which may fall outside of the period under audit. For one sample, management did not retain the evidence of income level relevant to the year under audit as the information was overwritten by a recertification that occurred subsequent to the fiscal year end. Also, in instances where patients are not able to present an SPBP card but intend to use that as a means to verify income status, management?s standard process is to call the SPBP program to confirm the patient?s SPBP status. The social worker documents the results of the call in the patient file. Management?s standard process does not comply with the Ryan White Certification Form Instructions which requires a copy of the undated card to be retained, in addition to confirmation of the patient?s status via phone. For two samples, the patient file included documentation of the phone call made by the Social Worker to SPBP, but did not include a copy of the patient?s SPBP card. Effect Patient care may be provided to ineligible patients. Questioned Costs None, as a form of documentation to support eligibility was ultimately provided for each patient. Recommendation The University should ensure proper documentation is retained to support all eligibility requirements, including level of income. Management should implement a periodic review control to detect any patients who are missing eligibility documentation and obtain the missing documentation. Finally, the AACO programs should implement a process to ensure each patient?s income verification is retained for a sufficient period of time. Management?s View and Corrective Action Plan Following this finding is management's view and corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-003 is an additional finding included in the report based upon the results of the audit of the University of Pennsylvania?s City of Philadelphia Awards. As this program includes Federal funding, it has also been included within this report. 2019-003 Eligibility Grantor: Department of Health and Human Services, Pass-through City of Philadelphia, AIDS Activity Coordinating Office (AACO) Program: Ryan White HIV/AIDS Title: HIV Emergency Relief Project Grants CFDA: 93.914 Award Year: 2018-2019, 2019-2020 Award Number: 1720668-01 (RW8668, RW8969); 1720668-02 (RW9668, RW9969) Criteria Per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, ?The certification process must begin for all clients upon initial intake for services and final eligibility is determined once all supporting documentation has been received and verified.? Additionally, the form states copies of all documentation are to be retained by the Provider. The City of Philadelphia Audit Guide section 6130.04 provides a list of documents to be maintained and states ?case management service providers are required to keep a file on each client served.? Additionally, per the Ryan White Client Certification Form Instructions provided to management by the AIDS Activity Coordinating Office, if the client presents an active Special Pharmaceutical Benefits Program (SPBP) card, the client has satisfied the income requirement without need for any additional supporting documentation. A copy of the card should be retained on file and status should be verified for cards without an expiration date. Status can be verified by calling the SPBP program with the number on the card. Condition Health Resources and Services Administration of the Department of Health and Human Services standards require service providers who receive Ryan White funding to screen clients and collect documentation to support the patient?s eligibility for Ryan White funded services, including but not limited to an HIV positive diagnosis, identity, residency, insurance status, and income level. These requirements were sent to the University of Pennsylvania (?the University?) by the City of Philadelphia as part of its contract to provide services. For the AACO Medical awards, 3 of a sample of 60 patient files selected for eligibility testing did not contain sufficient evidence of income level to support the Provider?s eligibility determination. Cause Management retains income support for the most recent eligibility determination which may fall outside of the period under audit. For one sample, management did not retain the evidence of income level relevant to the year under audit as the information was overwritten by a recertification that occurred subsequent to the fiscal year end. Also, in instances where patients are not able to present an SPBP card but intend to use that as a means to verify income status, management?s standard process is to call the SPBP program to confirm the patient?s SPBP status. The social worker documents the results of the call in the patient file. Management?s standard process does not comply with the Ryan White Certification Form Instructions which requires a copy of the undated card to be retained, in addition to confirmation of the patient?s status via phone. For two samples, the patient file included documentation of the phone call made by the Social Worker to SPBP, but did not include a copy of the patient?s SPBP card. Effect Patient care may be provided to ineligible patients. Questioned Costs None, as a form of documentation to support eligibility was ultimately provided for each patient. Recommendation The University should ensure proper documentation is retained to support all eligibility requirements, including level of income. Management should implement a periodic review control to detect any patients who are missing eligibility documentation and obtain the missing documentation. Finally, the AACO programs should implement a process to ensure each patient?s income verification is retained for a sufficient period of time. Management?s View and Corrective Action Plan Following this finding is management's view and corrective action plan.
Results of the eligibility audit finding were discussed with the Infectious Diseases/Ryan White Grant Program Manager at HUP, Morgan Curran. In the cases of the 2 missing copies of SPBP cards, this is mostly a timing issue. As of the date of this audit report, Morgan Curran has already reached out to the 2 patients with missing copies of SPBP cards to instruct them to bring their cards to the clinic with them at their next appointment. She also placed a note in their files instructing the check-in staff to obtain and the save the documentation in the patient files at such time. Regarding the missing income documentation, earlier in the year, the Program Manager designated 2 locked file cabinets where patient income documentation for these Ryan White awards is retained even after recertification occurs. Unfortunately, the missing income documentation was from the time period prior to the establishment of these secured file cabinets. Additionally, going forward, the clinic will perform an enhanced review of the documentation on file to support eligibility determinations at the time of patient certification or recertification.
FAC accepted this audit on February 18, 2019 — management decision was due August 18, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-008
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-005
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on February 21, 2018 — management decision was due August 21, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-005
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.