EIN: 251666090
UEI: GBYKKNK9SAE5
Audited by: MAHER DUESSEL, CPAS
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 3, 2026. 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 December 3, 2026 (96 days from today).
What is a management decision? →The Foundation did not consistently follow its established controls requiring independent review and approval of drawdown reimbursement requests prior to submission. During our testing of drawdown request controls within the Research and Development Cluster, we noted that 4 of 66 drawdown reimbursement requests tested (the entire population of drawdown requests) were submitted without documentation of independent review and approval. Based on the requests tested, the amounts submitted were accurate supported, and no instances of noncompliance were identified. Cause: The exceptions appear to have resulted from oversight in the review process, which led to drawdown requests being submitted before approval was documented. Additionally, the exceptions occurred during a period in which the Foundation was transitioning finance personnel responsibilities. Effect: Certain drawdown requests were submitted before the Foundation’s key control was evidenced as having been performed. Repeat Finding: N/A Questioned Costs: None Recommendation: We recommend the Foundation strengthen procedures to ensure all drawdown requests are reviewed and approved by the appropriate independent party prior to submission and that evidence of such review is consistently maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2025-001: Research and Development Cluster Cash Management Draw Approvals Federal Agency: Department of Health and Human Services Criteria: 2 CFR 200.303 requires the recipient to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance the award is managed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Foundation has established independent review and approval of drawdown requests by the CEO/Controller as key control over draw requests. Condition: The Foundation did not consistently follow its established controls requiring independent review and approval of drawdown reimbursement requests prior to submission. During our testing of drawdown request controls within the Research and Development Cluster, we noted that 4 of 66 drawdown reimbursement requests tested (the entire population of drawdown requests) were submitted without documentation of independent review and approval. Based on the requests tested, the amounts submitted were accurate supported, and no instances of noncompliance were identified. Cause: The exceptions appear to have resulted from oversight in the review process, which led to drawdown requests being submitted before approval was documented. Additionally, the exceptions occurred during a period in which the Foundation was transitioning finance personnel responsibilities. Effect: Certain drawdown requests were submitted before the Foundation’s key control was evidenced as having been performed. Repeat Finding: N/A Questioned Costs: None Recommendation: We recommend the Foundation strengthen procedures to ensure all drawdown requests are reviewed and approved by the appropriate independent party prior to submission and that evidence of such review is consistently maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See attached corrective action plan.
Veterans’ Health Foundation Corrective Action Plan Federal Drawdown Internal Control Finding 2025-001 Management agrees with the finding. The identified exceptions resulted from inconsistent retention of documented review evidence during a period of transition in finance personnel. While drawdown requests were supported by allowable expenditures and subject to financial oversight, documentation evidencing the control was not consistently maintained for certain transactions. To strengthen internal controls over federal drawdown requests and ensure continued compliance with 2 CFR 200.303, the Veterans Health Foundation will revise and formalize its drawdown procedures as follows: 1. Federal drawdown requests will be prepared by designated finance personnel and supported by appropriate expenditure documentation. 2. The Controller will review supporting documentation and authorize all federal drawdown requests prior to submission to ensure the accuracy, allowability, and appropriateness of reimbursement requests. 3. The CEO will perform and document a monthly reconciliation review of drawdown activity and related expenditures as an additional oversight and monitoring control. 4. The Foundation will update its formal policies and procedures within 60 days to reflect the revised drawdown preparation, review, authorization, reconciliation, and documentation retention requirements. 5. The Foundation is strengthening its document storage and records retention processes to ensure supporting documentation for drawdowns and other federal award activities is consistently maintained, centrally stored, and readily accessible for audit and compliance purposes. 6. As part of the Foundation’s broader administrative modernization initiative, the Foundation is implementing a new cloud-based file storage and records management system during the current fiscal year to improve document retention, access controls, continuity of operations, and long-term compliance oversight. 7. Management has communicated the revised control procedures to finance personnel and will monitor compliance with the updated process. The Foundation believes these corrective actions adequately address the finding and strengthen internal controls over federal cash management activities and records retention. Responsible Officials: Controller and Chief Executive Officer Anticipated Completion Date: Policy updates will be completed within 60 days. All other corrective actions have been implemented effective immediately, with the new cloud-based file storage system to be implemented during the current fiscal year.
FAC accepted this audit on May 16, 2025 — management decision was due November 16, 2025.
FAC accepted this audit on May 8, 2024 — management decision was due November 8, 2024.
FAC accepted this audit on May 21, 2023 — management decision was due November 21, 2023.
FAC accepted this audit on May 25, 2022 — management decision was due November 25, 2022.
FAC accepted this audit on May 18, 2021 — management decision was due November 18, 2021.
FAC accepted this audit on July 7, 2020 — management decision was due January 7, 2021.
Of the two procurements tested, the Foundation did not receive any competitive quotes for one of the purchases, nor was a vendor selection justification form completed (to support procurement by noncompetitive proposal). Questioned Costs: The sliding microtome was purchased for $17,873. Context: Without the evidence of competitive quotes for the above-mentioned equipment, it is uncertain whether the Foundation procured this sliding microtome from the lowest, responsible vendor. The equipment was purchased from a reputable vendor and for a reasonable price. Cause/Effect: The Foundation did not follow procurement policies regarding this purchase. As a result, no competitive quotes were received for this purchase, nor was a vendor selection justification form completed. Identification as a Repeat Finding: No single audit was required in the prior year. Recommendation: The Foundation should train all staff on its internal control system surrounding procurement to ensure that all equipment purchases are made in accordance with the Foundation?s internal policies and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See separate corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-001: Bidding Documentation Program Name: Research and Development Cluster (R&D) Criteria of Specific Requirement: In accordance with 2 CFR 200.320, procurement by small purchase procedures (above micro-purchases but below the Simplified Acquisition Threshold) must obtain price or rate quotations from an adequate number of qualified sources. Condition: Of the two procurements tested, the Foundation did not receive any competitive quotes for one of the purchases, nor was a vendor selection justification form completed (to support procurement by noncompetitive proposal). Questioned Costs: The sliding microtome was purchased for $17,873. Context: Without the evidence of competitive quotes for the above-mentioned equipment, it is uncertain whether the Foundation procured this sliding microtome from the lowest, responsible vendor. The equipment was purchased from a reputable vendor and for a reasonable price. Cause/Effect: The Foundation did not follow procurement policies regarding this purchase. As a result, no competitive quotes were received for this purchase, nor was a vendor selection justification form completed. Identification as a Repeat Finding: No single audit was required in the prior year. Recommendation: The Foundation should train all staff on its internal control system surrounding procurement to ensure that all equipment purchases are made in accordance with the Foundation?s internal policies and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See separate corrective action plan.
Finding 2019-001: Bidding Documentation Program Name: Research and Development Cluster (R&D) Condition: Of the two procurements tested, the Foundation did not receive any competitive quotes for one of the purchases, nor was a vendor section justification form completed (to support procurement by noncompetitive proposal). Recommendation: The Foundation should train all staff on its internal control system surrounding procurement to ensure that all equipment purchases are made in accordance with the Foundation's internal policies and uniform guidance. Action Taken: We concur with the recommendation and it was implemented immediately. Appropriate staff were referred to the Foundation's current internal purchasing-related policies and to uniform guidance. All information is available on the Foundation's website for easy access by appropriate staff. Management will monitor this issue regularly during the year to ensure compliance.
A sample of 3 transactions charged to R&D awards was tested during the current year audit. No formal documentation existed to show that the Foundation confirmed the vendors were not suspended or debarred. Questioned Costs: None Context: It is uncertain whether the above vendors were suspended or debarred at the time the above transactions occurred. However, as of June 2020 these vendors were not found to be suspended or debarred. Cause/Effect: There is no evidence to support that the Foundation followed suspension and debarment policies regarding these purchases. As a result, no evidence exists to support whether these vendors were debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Identification as a Repeat Finding: No single audit was required in the prior year. Recommendation: The Foundation should train all staff on its internal control system surrounding suspension and debarment to ensure that all purchases are made in accordance with the Foundation?s internal policies and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See separate corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-002: Suspension and Debarment Program Name: Research and Development Cluster (R&D) Criteria of Specific Requirement: In accordance with 2 CFR 200.213, non-federal entities are subject to the non-procurement debarment and suspension regulations. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition: A sample of 3 transactions charged to R&D awards was tested during the current year audit. No formal documentation existed to show that the Foundation confirmed the vendors were not suspended or debarred. Questioned Costs: None Context: It is uncertain whether the above vendors were suspended or debarred at the time the above transactions occurred. However, as of June 2020 these vendors were not found to be suspended or debarred. Cause/Effect: There is no evidence to support that the Foundation followed suspension and debarment policies regarding these purchases. As a result, no evidence exists to support whether these vendors were debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Identification as a Repeat Finding: No single audit was required in the prior year. Recommendation: The Foundation should train all staff on its internal control system surrounding suspension and debarment to ensure that all purchases are made in accordance with the Foundation?s internal policies and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See separate corrective action plan.
Finding 2019-002: Suspension and Debarment Program Name: Research and Development Cluster (R&D) Condition: A sample of three transactions charged to R&D awards was tested during the current year audit. No formal documentation existed to show that the Foundation confirmed that the vendors were not suspended or debarred. Recommendation: The Foundation should train all staff on its internal control system surrounding suspension and debarment to ensure that all purchases are made in accordance with the Foundation's internal policies and uniform guidance. Action Taken: We concur with the recommendation and it was implemented immediately. Appropriate staff were referred to the Foundation's current internal purchasing-related policies and to uniform guidance. Additionally, the Vendor Justification Form has been updated to ensure compliance with Debarment and Suspension requirements under uniform guidance, and a related Foundation policy is currently in the review and approval process. All information is available on the Foundation's website for easy access by appropriate staff. Management will monitor this issue regularly during the year to ensure compliance.
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