EIN: 316056230
UEI: EYMJXLN2MFB4
010782751, 020627166, 311024403, 311036370, 311296332, 311439570, 311595013, 311609283, 311654000, 311665952, 314379441 · unlinked EINs have no separate FAC filing
Audited by: Ernst & Young
Cognizant agency: 93 [Department of Health and Human Services]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 31, 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 January 31, 2027 (151 days from today).
What is a management decision? →FAC accepted this audit on September 2, 2025 — management decision was due March 2, 2026.
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.
Show full finding ▾Hide full finding ▴Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) 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 statutes, 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’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.
Finding 2023-001 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Suspension and Debarment Award Year: Fiscal year 2023 1/1/2023 – 12/31/2023 Award Number: None Corrective Action Plan and Anticipate Completion Date Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. o Management Response: In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has already been remediated. Upon finalization of the remediation details from the September 2023 finding, Management implemented remediation in Q4 2023 to address this finding. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. o Management Response: In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has already been remediated. Upon finalization of the remediation details from the September 2023 finding, Management implemented remediation to address this finding for the annual screening that was performed in Q1 2024 for year 2023. Management also implemented a monthly reconciliation process as quickly as practicable, beginning with January 2024 data. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. o Management Response: In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has already been remediated. Management implemented a process to verify the accuracy of the results produced by the third-party vendor. Management implemented the remediation to address the finding in the first quarter of 2024 for 4th quarter 2023 results. Responsible Person: Kathleen Dunn, JD – VP and Chief Compliance Officer Completion Date: January 31, 2024 • In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor was set up in the procurement system. o Management Response In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has already been remediated. Management implemented an audit process to ensure that screening documentation is maintained. This audit process flagged 2 of these 3 deficient documentation results, and documentation was subsequently uploaded to the file. The third vendor was an insurance company, which prior to mid-2023 was not screened at the time of setup based on vendor type. As of mid-2023, all vendors regardless of vendor type, are being screened at setup. Responsible Person: Mary Beth Colatruglio, CPA – Director of Accounting Completion Date: January 31, 2024
2022-001
There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas. Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.
Show full finding ▾Hide full finding ▴Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) 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 statutes, 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’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas. Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.
Finding 2023-002 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Fringe Rate Analysis – Formula Error Award Year: Fiscal year 2023 1/1/2023 – 12/31/2023 Award Number: Various Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Corrective Action Plan and Anticipate Completion Date Management’s corrective action plan includes: • Management will ensure a more robust review of the underlying formulas. Responsible Person: Natasha Collins, Director of Research Accounting Completion Date: December 31, 2024
Effort certifications were not timely reviewed and approved consistently for all employees’ salaries and wages for the year ended December 31, 2023. Cause: The Corporation has internal controls in place to require effort certifications be approved for all employees who charge effort to the R&D Cluster. However, they are not robust enough to ensure effort certification are reviewed timely. Effect or potential effect: Effort certifications were not timely reviewed; therefore, there is a risk that inaccurately reported effort is not timely identified. Questioned costs: None Context: We tested a sample of 40 salaries and wages ($20,924) and noted two instances ($2,746) where the effort report was not reviewed timely. Total salaries and wages charged to the R&D Cluster were $35,344,051 for the year ended December 31, 2023. Section III—Federal Award Findings and Questioned Costs (continued) The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-002. Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the R&D Cluster. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training.
Show full finding ▾Hide full finding ▴Finding 2023-003 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.110 Maternal and Child Health Federal Consolidated Programs 2 U03MC28844-09-00 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) 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 statutes, 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’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Effort certifications were not timely reviewed and approved consistently for all employees’ salaries and wages for the year ended December 31, 2023. Cause: The Corporation has internal controls in place to require effort certifications be approved for all employees who charge effort to the R&D Cluster. However, they are not robust enough to ensure effort certification are reviewed timely. Effect or potential effect: Effort certifications were not timely reviewed; therefore, there is a risk that inaccurately reported effort is not timely identified. Questioned costs: None Context: We tested a sample of 40 salaries and wages ($20,924) and noted two instances ($2,746) where the effort report was not reviewed timely. Total salaries and wages charged to the R&D Cluster were $35,344,051 for the year ended December 31, 2023. Section III—Federal Award Findings and Questioned Costs (continued) The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-002. Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the R&D Cluster. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training.
Finding 2023-003 Grantor: Department of Health and Human Services Federal Program: Oral Diseases and Disorders Research Maternal and Child Health Federal Consolidated Programs Assistance Listing #: 93.121 93.110 Title: Effort Certification Award Year: Fiscal year 2023 1/1/2023 – 12/31/2023 Award Number: 1R01DE031756-01A1 2 U03MC28844-09-00 Corrective Action Plan and Anticipate Completion Date • In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been remediated. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training. Responsible person: Aaron Ufferman, Director, Sponsored Projects Completion Date: February 1, 2024
2022-002
FAC accepted this audit on October 1, 2023 — management decision was due April 1, 2024.
Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Show full finding ▾Hide full finding ▴Finding 2022 ? 001 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.127 Emergency Medical Services For Children 5 U03MC28844-07-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 1 R01CE003349-01-00 93.136 Injury Prevention And Control Research And State And Community Based Programs 5 R49CE003074-03-00 93.137 Community Programs To Improve Minority Health Grant Program 5 CPIMP201202-02-00 93.242 Mental Health Research Grants 5R01MH117594-04 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-02-00 93.297 Teenage Pregnancy Prevention Program 5 TP1AH000212-03-00 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U54CA231641-01 93.353 21ST Century Cures Act ? Beau Biden Cancer Moonshot 1U01CA232488-01 93.378 Integrated Care For Kids Model 2B2CMS331798-03-00 Centers for Medicare & Medicaid Services 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Children?s Trust Fund 93.837 Cardiovascular Disease Research 5R01HL135103-05 93.837 Cardiovascular Disease Research 5R01HL157491-02 93.838 Lung Disease Research 1R01HL157039-01 93.838 Lung Disease Research 5R01HL157039-02 93.839 Blood Disease And Resources Research 1R01HL157208-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073908-03Assistance Listing Award Name Award Number Pass-Through Agency 93.846 Arthritis, Musculoskeletal And Skin Disease Research 1R01AR078395-01A1 93.846 Arthritis, Musculoskeletal And Skin Disease Research 5R01AR073311-04 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 1R01DK128088-01A1 93.847 Diabetes, Digestive, And Kidney Disease Extramural Research 5U01DK100866-09 93.855 Allergy And Infectious Disease Research 1R01AI151175-01A1 93.855 Allergy And Infectious Disease Research 5R01AI126890-05 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI146581-02 93.855 Allergy And Infectious Disease Research 5R01AI096882-09 93.855 Allergy And Infectious Disease Research 5R01AI116917-08 93.855 Allergy And Infectious Disease Research 5R01AI114581-07 93.865 Child Health And Human Development Extramural Research 5R01HD095976-03 93.865 Child Health And Human Development Extramural Research 5R01HD091347-04 93.865 Child Health And Human Development Extramural Research 5R01HD098175-02 93.865 Child Health And Human Development Extramural Research 5R01HD100420-02 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 93.870 Maternal, Infant And Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control:?The non-Federal entity must: (a) 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 statutes, 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? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Section 200.214 Suspension and Debarment ?Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 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: Nationwide Children?s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: ? The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. ? The Corporation does not have a process to reconcile the vendor list provided to the thirdparty with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. ? The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate.In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the ?new? vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management?s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation?s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2022 and noted four instances where management did not retain the supporting documents of its review of suspension and debarment for the vendor.The federal portion of procurement expenditures subject to suspension and debarment was $10,415,440 which represents approximately 12.3% of the R&D Cluster federal expenditures. The total amount reported on the SEFA for the R&D cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should implement the following internal controls: ? The monthly suspension and debarment review process ? Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the thirdparty vendor ? Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors
Finding 2022-001 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Pass-through Grantor Pass-Through Award Number Pass-through Award Period None None None Award Year: Fiscal year 2022 1/1/2022 ? 12/31/2022 Award Number: None Management agrees with the recommendation. Management will implement the following changes to Time and Effort practices. Corrective Action Plan and Anticipate Completion Date Management agrees with the recommendation. ? Review suspension and debarment? Management will review the monthly third-party vendor screening results. Management will retain documentation of the review and supporting documents used in the review. ? Reconciliation ? Management will implement a process to reconcile the number of vendor files sent to the third-party screening vendor with the number screened. Management will memorialize this reconciliation. ? Accuracy ? Management will implement a process to verify the accuracy of the results produced by the third-party vendor. Management will memorialize this review. Responsible Person: Kathleen Dunn, JD ? VP and Chief Compliance Officer Effective Date: October 1, 2023 Management?s corrective action plan includes: ? Initial screening ? Management will implement a process to ensure that supporting documentation of the initial screening process is maintained. Responsible Person: Mary Beth Colatruglio, CPA ? Director of Accounting Effective Date: October 1, 2023
The Corporation did not obtain effort certifications consistently for all employees? salaries and wages for the year ended December 31, 2022. Effort certifications were not timely reviewed and approved consistently for all employees? salaries and wages for the year ended December 31, 2022. Cause: The Corporation has internal controls in place to require effort certifications be retained for all employees who charge effort to the R&D Cluster, however, they are not suitably designed to ensure certifications are obtained for all employees and on a timely basis. Section III?Federal Award Findings and Questioned Costs (continued) Effect or potential effect: The Corporation charged salary expense for employees who did not certify their time; therefore, the salaries charged to the program could not be supported. Effort certifications were not timely received; therefore, the effort certified may not be accurate. Questioned costs: $17,639 which includes the salaries and wages charged to the grant plus the related fringe and indirect expenses. Award Information: Assistance Listing 93.297 Teenage Pregnancy Prevention Program: Award No: 5 TP1AH000212-02-00 ? $2,555 Assistance Listing 93.855 Allergy And Infectious Diseases Research: Award No.: 5R01AI126890-05 ? $828 5U01AI131386-05 ? $10,963 5R01AI146581-02 ? $3,293 Context: We tested a sample of 40 salaries and wages ($161,265) and noted 4 instances ($17,639) where management did not obtain effort reports to support the salaries and wages charged to the R&D Cluster. In addition, we noted five instances ($4,262) where the effort report was not signed timely. Section III?Federal Award Findings and Questioned Costs (continued) Total salaries and wages charged to the R&D Cluster were $31,468,443 for the year ended December 31, 2022. The total amount reported on the Schedule for the R&D Cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are received and received timely for all employees charging effort to the R&D Cluster.
Show full finding ▾Hide full finding ▴Finding 2022 ? 002 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name and Award Number: ? 93.297 Teenage Pregnancy Prevention Program ? Award No: 5 TP1AH000212-02-00 ? 93.855 Allergy And Infectious Diseases Research ? Award No: 5R01AI126890-05, 5U01AI131386-05; and 5R01AI146581-02 Pass-Through Grantor: None Pass-Through Award Number: None Pass-Through Award Period: Various Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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 statutes, regulations, and the terms and conditions of the Federal Section III?Federal Award Findings and Questioned Costs (continued) award. These internal controls should be in compliance with guidance in `Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 45 CFR Part 75 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, Appendix IX to Part 75?Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts with Hospitals, states: ?Charges for salaries and wages of individuals other than members of the professional staff will be supported by daily time and attendance and payroll distribution records. For members of the professional staff, current and reasonable estimates of the percentage distribution of their total effort may be used as support in the absence of actual time records.? ?In order to qualify as current and reasonable, estimates must be made no later than one month (though not necessarily a calendar month) after the month in which the services were performed. Estimates determined before the performance of services, such as budget estimates on a monthly, quarterly, or yearly basis do not qualify as estimates of effort spent.? Condition: The Corporation did not obtain effort certifications consistently for all employees? salaries and wages for the year ended December 31, 2022. Effort certifications were not timely reviewed and approved consistently for all employees? salaries and wages for the year ended December 31, 2022. Cause: The Corporation has internal controls in place to require effort certifications be retained for all employees who charge effort to the R&D Cluster, however, they are not suitably designed to ensure certifications are obtained for all employees and on a timely basis. Section III?Federal Award Findings and Questioned Costs (continued) Effect or potential effect: The Corporation charged salary expense for employees who did not certify their time; therefore, the salaries charged to the program could not be supported. Effort certifications were not timely received; therefore, the effort certified may not be accurate. Questioned costs: $17,639 which includes the salaries and wages charged to the grant plus the related fringe and indirect expenses. Award Information: Assistance Listing 93.297 Teenage Pregnancy Prevention Program: Award No: 5 TP1AH000212-02-00 ? $2,555 Assistance Listing 93.855 Allergy And Infectious Diseases Research: Award No.: 5R01AI126890-05 ? $828 5U01AI131386-05 ? $10,963 5R01AI146581-02 ? $3,293 Context: We tested a sample of 40 salaries and wages ($161,265) and noted 4 instances ($17,639) where management did not obtain effort reports to support the salaries and wages charged to the R&D Cluster. In addition, we noted five instances ($4,262) where the effort report was not signed timely. Section III?Federal Award Findings and Questioned Costs (continued) Total salaries and wages charged to the R&D Cluster were $31,468,443 for the year ended December 31, 2022. The total amount reported on the Schedule for the R&D Cluster is $82,409,498. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are received and received timely for all employees charging effort to the R&D Cluster.
Finding 2022-002 Grantor: Department of Health and Human Services Federal Program: Teenage Pregnancy Prevention Program Allergy And Infectious Diseases Research Assistance Listing #: 93.267 93.855 Pass-through Grantor Pass-Through Award Number Pass-through Award Period None None Various Award Year: Fiscal year 2022 1/1/2022 ? 12/31/2022 Award Number: 5 TP1AH000212-02 5R01AI126890-05 5U01AI131386-05 5R01AI146581-02 Management agrees with the recommendation. Management will implement the following changes to Time and Effort practices. Corrective Action Plan and Anticipated Completion Date Management?s corrective action plan includes: ? Review and revise Time and Effort internal policy to include more robust internal controls. ? Develop escalation procedures for delayed certification. ? Outstanding time and efforts to be certified. Responsible person: Aaron Ufferman, Director, Sponsored Projects Completion Date: December 31, 2023.
The Schedule of Expenditures of Federal Awards prepared by the Corporation did not appropriately reflect the federal expenses related to the R&D Cluster. The final Schedule was corrected for the differences identified. Cause: The Corporation did not design internal controls over the review and approval of the Schedule to ensure the appropriate federal awards were included in the R&D Cluster. Section III?Federal Award Findings and Questioned Costs (continued) Effect or potential effect: Federal awards were inappropriately included and excluded from the R&D Cluster. Questioned costs: None Context: Total R&D Cluster expenses included on the draft Schedule were $84,223,943 for the year ended December 31, 2022. Total R&D expenses included on the final Schedule were $82,409,498 for the year ended December 31, 2022. Total expenditures on the Schedule did not change. See the federal programs added and removed from the R&D Cluster in the Information on Federal Programs section above. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: We recommend that management implement more robust management review internal controls to ensure accurate reporting of federal awards on the Schedule.
Show full finding ▾Hide full finding ▴Finding 2022 ? 003 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No, Award Name, Award Number and Pass-through Entity: These federal awards were added to the R&D Cluster: Assistance Listing Award Name Award Number Pass-Through Entity 93.127 Emergency Medical Services For Children EIIC University Hospitals Cleveland Medical Center 93.226 Research On Healthcare Costs, Quality and Outcomes 1R01HS029183-01 93.361 Nursing Research FY22.1180.001 University of Colorado Denver 93.575 Child Care and Development Block Grant Ohio Children?s Alliance Ohio Children?s Alliance 93.596 Child Care Mandatory And Matching Funds of the Child Care and Development Fund COVID-19 Ohio Child Care Resource and Referral Association 93.838 Lung Diseases Research 10059528-01-NWC The University of Utah 93.846 Arthritis, Musculoskeletal and Skin Diseases Research GRANT ID: GRT-00001510 Children?s Hospital of Philadelphia 93.855 Allergy and Infectious Diseases Research 034146-014 Arkansas Children?s Hospital Research Institute 93.855 Allergy and Infectious Diseases Research A635027 Emory University 93.855 Allergy and Infectious Diseases Research OS00000060/317962 Cincinnati Children?s Hospital Medical Center 93.865 Child Health and Human Development Extramural Research 9116-NCH Indiana University 93.865 Child Health and Human Development Extramural Research A21-0255-S002 UC Davis Medical Center 93.867 Vision Research CONTRACT ID 1803 JAEB Center For Health Section III?Federal Award Findings and Questioned Costs (continued) These federal awards were removed from the R&D Cluster: Assistance Listing Award Name Award Number Pass-Through Entity 16.575 Crime Victim Assistance 2022-SVAA-134716708 Crime Victims Assistance 16.575 Crime Victim Assistance 2022-VOCA-134716701 Crime Victims Assistance 16.575 Crime Victim Assistance 2022DVF42 Crime Victims Assistance 16.575 Crime Victim Assistance 2023-VOCA-135104760 Crime Victims Assistance 21.019 Coronavirus Relief Fund 2020-CARES-78 Crime Victims Assistance 93.110 Maternal and Child Health Federal Consolidated Programs 1 R40MC37541-01-00 93.110 Maternal and Child Health Federal Consolidated Programs RPPN University Hospitals Cleveland Medical Center 93.110 Maternal and Child Health Federal Consolidated Programs GR124424/SPC-1000005299 The Ohio State University 93.110 Maternal and Child Health Federal Consolidated Programs GR127800 SPC-1000006745 The Ohio State University 93.110 Maternal and Child Health Federal Consolidated Programs MCHB 436 22-23 Hemophilia Foundation of Michigan 93.558 Temporary Assistance for Needy Families 25-21-3536 Franklin County Department of Job And Family Services 93.575 Child Care and Development Block Grant IECMH Ohio Children?s Alliance 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246 Ohio Childrens Trust Fund 93.590 Community-Based Child Abuse Prevention Grants G-2223-22-0246-1 Ohio Childrens Trust Fund 93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service GR125049 The Ohio State University 93.632 University Centers for Excellence in Developmental Disabilities Education, Research, and Service GR128419 The Ohio State University 93.778 Medical Assistance Program GR124661 The Ohio State University 93.870 Maternal, Infant and Early Childhood Home Visiting Grant 02560511MH0622 Ohio Department of Health 93.959 Block Grants for Prevention and Treatment of Substance Abuse 2200026 Ohio Department of Mental Health Section III?Federal Award Findings and Questioned Costs (continued) Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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 statutes, 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? issued by the Comptroller General of the United States or the `Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards prepared by the Corporation did not appropriately reflect the federal expenses related to the R&D Cluster. The final Schedule was corrected for the differences identified. Cause: The Corporation did not design internal controls over the review and approval of the Schedule to ensure the appropriate federal awards were included in the R&D Cluster. Section III?Federal Award Findings and Questioned Costs (continued) Effect or potential effect: Federal awards were inappropriately included and excluded from the R&D Cluster. Questioned costs: None Context: Total R&D Cluster expenses included on the draft Schedule were $84,223,943 for the year ended December 31, 2022. Total R&D expenses included on the final Schedule were $82,409,498 for the year ended December 31, 2022. Total expenditures on the Schedule did not change. See the federal programs added and removed from the R&D Cluster in the Information on Federal Programs section above. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: We recommend that management implement more robust management review internal controls to ensure accurate reporting of federal awards on the Schedule.
Finding 2022-003 Grantor: Department of Agriculture and Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Schedule of Expenditures of Federal Awards Award Year: Fiscal year 2021 1/1/2022 ? 12/31/2022 Award Number: Various Management agrees with the recommendation. Management will implement the following changes to the management of the Schedule of Expenditures. Corrective Action Plan and Anticipate Completion Date Management?s corrective action plan includes: ? Review and validate that grants are listed under the correct cluster. Responsible Person: Aaron Ufferman, Director, Sponsored Projects, Natasha Collins, Director of Research Accounting Completion Date: December 31, 2023
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
Management did not retain documentation over the review and approval of the PRF terms and conditions reporting (T&Cs). Management did not retain documentation over its review and approval of the lost revenue calculation and the report submitted in the HHS HRSA portal. Management did not retain supporting documentation over certain payroll expenses. Total expenses reported in the HHS portal for period 1 and period 2 did not agree to the books and records of Nationwide. Cause: Management did not have suitably designed internal controls over the review and approval of the T&Cs, the lost revenue calculation, and HHS HRSA portal submission. Management did not have internal controls in place to require supporting documentation of payroll expenses charged to the PRF program be retained. Effect or potential effect: The lack of documentation of the PRF T&Cs could result in Nationwide not being in compliance with the PRF T&Cs. The lack of documentation of the review and approval of the lost revenue calculation and portal submission could result in error in the lost revenue calculation or report submitted to the HHS HRSA portal. The lack of review and approval of expenses used for PRF reporting resulted in unallowable expenses being charged to the PRF program. Questioned costs: Assistance Listing No. 93.498, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? total questioned costs are $64,171. ? $6,741 relates to employees where supporting documentation for their PRF payroll was not available ? $57,430 relates to expenses charged to the PRF program in excess of actual program expenses Context: We selected a sample of 40 payroll transactions totaling $67,209 and noted three payroll selections totaling $6,471 that management was unable to provide support that they were related to COVID-19. Total payroll expense was $16,849,658. Total PRF expenses reported in the portal for Periods 1 and 2 were $3,635,748 and actual PRF expense were $3,578,318; the difference of $57,430 could not be supported. Nationwide reported expense in period 1 of $19,233,526, while actual expenses were $18,916,134. NCH report expenses in Period 2 of $1,997,042 while actual expenses were $3,635,748, We noted that $809,301 of the difference represented an understatement of expenses in Period 1 and an overstatement of expenses in Period 2 for the same amount. The remaining difference of $57,430 is described in the above paragraph. Total PRF lost revenue and expenditures reported on the schedule of federal awards are $81,583,962 for the year ended December 31, 2021. Identification as a repeat finding, if applicable: This is not a repeat finding.
Show full finding ▾Hide full finding ▴Section III ? Federal Award Findings and Questioned Costs Finding 2021-001 Information on the federal program: Federal Program: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services (HHS) Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 Criteria or specific requirement (including statutory, regulatory, or other citation): The Uniform Guidance 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 statutes, 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? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements June 11, 2021 indicates that: ? Allowable equipment expenses include, ?Expenses paid for purchase of equipment used for infection control, such as updates to HVAC systems or sanitizing equipment.? ? ?The Reporting Entity will report on unreimbursed expenses attributable to coronavirus (net after other assistance received and PRF payments are applied).? ? ?Expenses that are paid for with General and Targeted PRF payments must be those that are unreimbursed by other sources and that other sources are not eligible to reimburse.? Condition: Management did not retain documentation over the review and approval of the PRF terms and conditions reporting (T&Cs). Management did not retain documentation over its review and approval of the lost revenue calculation and the report submitted in the HHS HRSA portal. Management did not retain supporting documentation over certain payroll expenses. Total expenses reported in the HHS portal for period 1 and period 2 did not agree to the books and records of Nationwide. Cause: Management did not have suitably designed internal controls over the review and approval of the T&Cs, the lost revenue calculation, and HHS HRSA portal submission. Management did not have internal controls in place to require supporting documentation of payroll expenses charged to the PRF program be retained. Effect or potential effect: The lack of documentation of the PRF T&Cs could result in Nationwide not being in compliance with the PRF T&Cs. The lack of documentation of the review and approval of the lost revenue calculation and portal submission could result in error in the lost revenue calculation or report submitted to the HHS HRSA portal. The lack of review and approval of expenses used for PRF reporting resulted in unallowable expenses being charged to the PRF program. Questioned costs: Assistance Listing No. 93.498, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? total questioned costs are $64,171. ? $6,741 relates to employees where supporting documentation for their PRF payroll was not available ? $57,430 relates to expenses charged to the PRF program in excess of actual program expenses Context: We selected a sample of 40 payroll transactions totaling $67,209 and noted three payroll selections totaling $6,471 that management was unable to provide support that they were related to COVID-19. Total payroll expense was $16,849,658. Total PRF expenses reported in the portal for Periods 1 and 2 were $3,635,748 and actual PRF expense were $3,578,318; the difference of $57,430 could not be supported. Nationwide reported expense in period 1 of $19,233,526, while actual expenses were $18,916,134. NCH report expenses in Period 2 of $1,997,042 while actual expenses were $3,635,748, We noted that $809,301 of the difference represented an understatement of expenses in Period 1 and an overstatement of expenses in Period 2 for the same amount. The remaining difference of $57,430 is described in the above paragraph. Total PRF lost revenue and expenditures reported on the schedule of federal awards are $81,583,962 for the year ended December 31, 2021. Identification as a repeat finding, if applicable: This is not a repeat finding.
Management?s corrective action plan includes: ? Document the review of the PRF terms and conditions and HHS filing by the CFO. ? Ensure that documentation related to expenses included in the HHS filing is complete and reconciles to the books and records of Nationwide Children?s Hospital. ? Incorporate any expenses reported in error into the 2023 HHS filing for PRF funds received in 2022.
FAC accepted this audit on March 24, 2022 — management decision was due September 24, 2022.
FAC accepted this audit on July 8, 2020 — management decision was due January 8, 2021.
FAC accepted this audit on June 17, 2019 — management decision was due December 17, 2019.
FAC accepted this audit on August 15, 2018 — management decision was due February 15, 2019.
FAC accepted this audit on June 27, 2017 — management decision was due December 27, 2017.
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