Dayton Children's HospitalNon-Profit

Finding 2019-001 (A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; C. Cash Management; G. Matching, Level of Effort, and Earmarking; H. Period of Performance; and L. Reporting) Information on the Federal Program Federal Grantor: U.S. Department of Justice Pass-Through Grantor: Ohio Attorney General CFDA No.: 16.575, Crime Victim Assistance Award Number: 2018-VOCA-132092046; 2019-VOCA-132136161; 2018-VOCA-109310214; 2019-VOCA-132136148; 2018-VOCA-109309260; 2019-VOCA-132136183; 2018-VOCA-109310243; and 2019-VOCA-132136152 Award Period: October 1, 2017 ? September 30, 2018 and October 1, 2018 ? September 30, 2019 Criteria or Specific Requirement (including statutory, regulatory or other citation) The 2 CFR section 200.303 states the non-Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government (also known as the Green Book) issued by the Comptroller General of the United States or the Internal Control ? Integrated Framework (COSO 2013 Framework) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition Dayton Children?s Hospital and Subsidiaries did not appropriately design or implement internal controls over the Crime Victims Assistance Major Federal program as of and the year ended June 30, 2019. Cause The Hospital does not have an understanding of, or training related to, the Green Book or the COSO 2013 Framework specific to the Uniform Guidance and requirements of their major federal program. Effect or Potential Effect If adequate controls are not designed and implemented, funds may not be expended in compliance with the grant agreements, or the Hospital may not take necessary actions required to comply with the grant agreements related to activities allowed or unallowed; allowable costs/cost principles; cash management; matching, level of effort, and earmarking; period of performance; and reporting. Questioned Costs None identified. Context This is only the second year the Hospital has been subject to the Uniform Guidance audit requirements. While management administers their grant with guidance from officials from the State of Ohio, they have not reviewed, adopted or maintained documents as outlined under the Green Book or the COSO 2013 Framework related to activities allowed or unallowed; allowable costs/cost principles; cash management; matching, level of effort, and earmarking; period of performance; and reporting. Identification as a Repeat Finding This is a repeat finding. See Finding 2018-002 in the June 30, 2018 Single Audit Report. Recommendation The Hospital should assess the compliance attributes of the Crime Victims Assistance Major Federal program and appropriately design and implement controls in accordance with requirements of the Uniform Guidance, the Green Book, and the COSO 2013 Framework. Management should maintain evidence of the existence and performance of such internal controls. View of Responsible Officials and Planned Corrective Action Management agrees with the comment.

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