EIN: 316059784
UEI: HLLDLCSRZKN5
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 28, 2024. 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 September 28, 2024 (694 days ago).
What is a management decision? →Assistance Listing. Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID-19: Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Award Identification Number and Year - N/A Pass-through Entity - N/A - Direct funded Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements dated April 7, 2023, recipients must meet compliance with reporting requirements as outlined in the Terms and Conditions of the funding received. The Terms and Conditions require that the funding recipient certify that it will not use the payments received to reimburse it for expenses or losses that have been reimbursed from other sources, or that other sources are obligated to reimburse. In addition, the Terms and Conditions state that net charges from patient care are to be used to calculate lost revenue amounts reported by quarter. Condition - The Corporation's controls in place for reporting submissions did not identify that the General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to certain reported lost revenue amounts in the Corporation’s Period 4 portal submissions. In addition, the Corporation's controls in place did not identify that lost revenue amounts for one subsidiary were reported at gross charges from patient care (compared to recording these amounts at net charges from patient care). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The single audit for the Corporation included four portal submissions related to funding received in Period 4. As a result of the funding received, the Organization was required to attest to the applicable expenses and lost revenues incurred, which are defined by HHS, as noted in the criteria above. In two Period 4 portal submissions, available lost revenue amounts reported by the Corporation were duplicated, resulting in approximately $58.2 million of lost revenue for one subsidiary being reported on two separate Period 4 portal submissions. In addition, the lost revenue amounts for one subsidiary were incorrectly reported at gross patient service revenues. This resulted in the reporting of approximately S6.4 million of lost revenue during the period of availability. The correct amount of lost revenues to be reported by the organization should have been $1.6 million. Cause and Effect - Appropriate review of the reporting submissions was not completed to ensure the reports followed required guidelines. As a result, the Corporation reported incorrect totals for lost revenue for the period 4 portal submissions. Recommendation - We recommended that the Corporation implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Corporation will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue amounts are used in future reporting periods.
Show full finding ▾Hide full finding ▴Assistance Listing. Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID-19: Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Award Identification Number and Year - N/A Pass-through Entity - N/A - Direct funded Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements dated April 7, 2023, recipients must meet compliance with reporting requirements as outlined in the Terms and Conditions of the funding received. The Terms and Conditions require that the funding recipient certify that it will not use the payments received to reimburse it for expenses or losses that have been reimbursed from other sources, or that other sources are obligated to reimburse. In addition, the Terms and Conditions state that net charges from patient care are to be used to calculate lost revenue amounts reported by quarter. Condition - The Corporation's controls in place for reporting submissions did not identify that the General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to certain reported lost revenue amounts in the Corporation’s Period 4 portal submissions. In addition, the Corporation's controls in place did not identify that lost revenue amounts for one subsidiary were reported at gross charges from patient care (compared to recording these amounts at net charges from patient care). Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The single audit for the Corporation included four portal submissions related to funding received in Period 4. As a result of the funding received, the Organization was required to attest to the applicable expenses and lost revenues incurred, which are defined by HHS, as noted in the criteria above. In two Period 4 portal submissions, available lost revenue amounts reported by the Corporation were duplicated, resulting in approximately $58.2 million of lost revenue for one subsidiary being reported on two separate Period 4 portal submissions. In addition, the lost revenue amounts for one subsidiary were incorrectly reported at gross patient service revenues. This resulted in the reporting of approximately S6.4 million of lost revenue during the period of availability. The correct amount of lost revenues to be reported by the organization should have been $1.6 million. Cause and Effect - Appropriate review of the reporting submissions was not completed to ensure the reports followed required guidelines. As a result, the Corporation reported incorrect totals for lost revenue for the period 4 portal submissions. Recommendation - We recommended that the Corporation implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Corporation will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue amounts are used in future reporting periods.
Condition: The Corporation's controls in place for reporting submissions did not identify that General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Corporation's Period 4 reporting submissions for lost revenue did not follow the acceptable options provided by HHS. Planned Corrective Action: The Corporation will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue methodology is used in future reporting periods. Contact person responsible for corrective action: Seth Marsh, Director of Enterprise-Wide Accounting Anticipated Completion Date: 6/30/2024
FAC accepted this audit on March 27, 2022 — management decision was due September 27, 2022.
CFDA Number, Federal Agency, and Program Name - CFDA #16.575, U.S. Department of Justice, Crime Victim Assistance Federal Award Identification Number and Year - 2019 VOCA 132136354 Pass through Entity - Ohio Attorney General Finding Type - Material weakness Repeat Finding - Yes, 2019 001 Criteria - Per 2 CFR 200.508(b), an auditee must prepare appropriate financial statements, including the schedule of expenditures of federal awards (SEFA), in accordance with 200.510, Financial Statements. In addition, per 2 CFR 200.510(b), 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, as determined in accordance with 200.502, Basis for Determining Federal Awards Expended. Condition - While the Corporation has a process in place to prepare the SEFA, the current process and controls did not ensure the SEFA was complete and accurate. Questioned Costs - Not applicable. Identification of How Questioned Costs Were Computed - Not applicable. Context - Related to CFDA 16.575, 5 out of the 60 allowable cost samples were not recorded in the proper fiscal year. The five samples totaled $27,341. The above mentioned activity all incurred in FY 2019. The FY 2020 SEFA was overstated by $27,341 to account for FY 2019 activity not reported on the FY 2019 SEFA. Cause and Effect - The Corporation's procedures for preparing the SEFA did not result in a schedule that was complete and accurate. Expenses incurred during FY 2019 were reported on the FY 2020 SEFA. Management evaluated whether correcting FY 2019 would result in additional major programs. FY 2019 major programs were not affected by the error. Thus, the FY 2020 SEFA is overstated by $27,341. The lack of appropriate controls can result in a SEFA that is not complete and accurate and improper major programs. Recommendation - The Corporation should establish a process to review the SEFA for completeness and accuracy to ensure that expenditures of federal awards are recorded in accordance with 2 CFR 200.510. Views of Responsible Officials and Corrective Action Plan - The SPO office, in collaboration with finance, will ensure that all processes are followed and reviewed to ensure proper SEFA completion.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - CFDA #16.575, U.S. Department of Justice, Crime Victim Assistance Federal Award Identification Number and Year - 2019 VOCA 132136354 Pass through Entity - Ohio Attorney General Finding Type - Material weakness Repeat Finding - Yes, 2019 001 Criteria - Per 2 CFR 200.508(b), an auditee must prepare appropriate financial statements, including the schedule of expenditures of federal awards (SEFA), in accordance with 200.510, Financial Statements. In addition, per 2 CFR 200.510(b), 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, as determined in accordance with 200.502, Basis for Determining Federal Awards Expended. Condition - While the Corporation has a process in place to prepare the SEFA, the current process and controls did not ensure the SEFA was complete and accurate. Questioned Costs - Not applicable. Identification of How Questioned Costs Were Computed - Not applicable. Context - Related to CFDA 16.575, 5 out of the 60 allowable cost samples were not recorded in the proper fiscal year. The five samples totaled $27,341. The above mentioned activity all incurred in FY 2019. The FY 2020 SEFA was overstated by $27,341 to account for FY 2019 activity not reported on the FY 2019 SEFA. Cause and Effect - The Corporation's procedures for preparing the SEFA did not result in a schedule that was complete and accurate. Expenses incurred during FY 2019 were reported on the FY 2020 SEFA. Management evaluated whether correcting FY 2019 would result in additional major programs. FY 2019 major programs were not affected by the error. Thus, the FY 2020 SEFA is overstated by $27,341. The lack of appropriate controls can result in a SEFA that is not complete and accurate and improper major programs. Recommendation - The Corporation should establish a process to review the SEFA for completeness and accuracy to ensure that expenditures of federal awards are recorded in accordance with 2 CFR 200.510. Views of Responsible Officials and Corrective Action Plan - The SPO office, in collaboration with finance, will ensure that all processes are followed and reviewed to ensure proper SEFA completion.
Finding Number: 2020-001 Condition: While the Corporation has a process in place to prepare the SEFA, the current process and controls did not ensure the SEFA was complete and accurate. Planned Corrective Action: We acknowledge the SEFA was incorrect due to a lack of operational control for marketing invoices on the SARNCO VOCA grant. Due to this lack of control, there was an instance where an invoice was received in October for work done in March that caused the SEFA to be incorrect. The main process that led to an incorrect SEFA for the fiscal year was the lack of control over the marketing invoices for the SARNCO VOCA grant. In the previous process, a blanket PO was set up for the marketing work at the beginning of the grant FY. The invoices would then be sent from marketing or vendor directly to the automated AP system to pay. This could lead to invoices not being processed properly by the AP system and/or the grants consultant not being aware of the invoice. If one of these instances occurred, the amount might not be accrued or processed by the end of the month in which the work occurred. We have developed comprehensive actions in order to prevent recurrence. As immediate corrections to this condition, we have taken the following actions: ? Grants consultant will contact Marketing / Vendor during the last week of each month to request current invoices for work completed during that month. Marketing / Vendor to provide invoices by last business day of the month. Grants consultant will work closely with Project/Program Manager to determine when work is started / completed to ensure the invoice is received for the work. ? Grants consultant to submit purchase requisitions for these invoices or utilize blanket PO for contracted work before Month End Process so invoices are entered into General Ledger and reported to funder in the same month that expenses are incurred ? Grants consultant to enter PO number(s) on each invoice as soon as they are sourced and send invoices to AP for payment, CC-ing Vendor contacts and OhioHealth Marketing ? Grants Consultant to work collaboratively with Finance to ensure that all submitted invoices are paid out in a timely manner This is the process that we followed to ensure we were receiving the invoices on time and the issue was corrected We had received this condition in a draft form in April 2020 and started updating the process. While the process was fully implemented by August 31, 2020 and applies to the fiscal year 2021 SEFA, we did start the process for the final month of the fiscal year 2020 SEFA. Contact Person Responsible for Corrective Action: Michael Brechbuhler Anticipated Completion Date: August 31, 2020
2019-001
CFDA Number, Federal Agency, and Program Name - CFDA #93.092, R&D Cluster U.S. Department of Health and Human Services Administration for Children and Families, Personal Responsibility Education Program Federal Award Identification Number and Year - 90AP2678 03 00 for 2018 2019 and 90AP2678 04 00 for 2019 2020 Pass through Entity - Direct funded Finding Type - Significant deficiency Repeat Finding - Yes, 2019 002 Criteria - 2 CFR 200.331 indicates all pass through entities must (a) ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification (when some of this information is not available, the pass through entity must provide the best information available to describe the federal award and subaward); (b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section; (c) consider imposing specific subaward conditions upon a subrecipient if appropriate, as described in ?200.207 Specific Conditions; and (d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition - The Corporation did not include all of the required information within the subrecipient agreements, nor did the Corporation evaluate its subrecipients' risk for noncompliance. Questioned Costs - Not applicable. Identification of How Questioned Costs Were Computed - Not applicable. Context - The review of subrecipient agreements and monitoring documentation provided by management indicated that the Corporation was not compliant with provisions of 2 CFR Section 200.331. The Corporation has two subrecipients, and their agreements excluded information that is necessary for the subrecipients to comply with the applicable laws and regulations, such as the CFDA Number, whether the award is R&D, the total amount of the award, and the period of performance. While the Corporation did not perform a risk assessment of each subrecipient, it reviewed all requests for reimbursement to ensure there was adequate support and that the activity was allowable and consistent with the terms and conditions of the grant. Cause and Effect - The Corporation did not review the requirements of 2 CFR 200.331 to ensure agreements were in compliance with the Uniform Guidance. Without providing the necessary information to subrecipients and the lack of risk assessments, subrecipients are at a greater risk of noncompliance, which can result in noncompliance and questioned costs for the Corporation. Recommendation - The Corporation should implement a process to ensure subrecipient agreements and/or the documentation provided to subrecipients aligns with the requirements in 2 CFR Section 200.331(a)(1). Additionally, the Corporation should document risk assessments and monitoring procedures completed on subrecipients in accordance with 2 CFR Section 200.331(b) and 2 CFR Section 200.331(d). Views of Responsible Officials and Planned Corrective Actions - The SPO office will follow guidelines put into place to ensure that subaward agreements have all the required information and that documentation is obtained for all subaward monitoring.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - CFDA #93.092, R&D Cluster U.S. Department of Health and Human Services Administration for Children and Families, Personal Responsibility Education Program Federal Award Identification Number and Year - 90AP2678 03 00 for 2018 2019 and 90AP2678 04 00 for 2019 2020 Pass through Entity - Direct funded Finding Type - Significant deficiency Repeat Finding - Yes, 2019 002 Criteria - 2 CFR 200.331 indicates all pass through entities must (a) ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and, if any of these data elements change, include the changes in subsequent subaward modification (when some of this information is not available, the pass through entity must provide the best information available to describe the federal award and subaward); (b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section; (c) consider imposing specific subaward conditions upon a subrecipient if appropriate, as described in ?200.207 Specific Conditions; and (d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition - The Corporation did not include all of the required information within the subrecipient agreements, nor did the Corporation evaluate its subrecipients' risk for noncompliance. Questioned Costs - Not applicable. Identification of How Questioned Costs Were Computed - Not applicable. Context - The review of subrecipient agreements and monitoring documentation provided by management indicated that the Corporation was not compliant with provisions of 2 CFR Section 200.331. The Corporation has two subrecipients, and their agreements excluded information that is necessary for the subrecipients to comply with the applicable laws and regulations, such as the CFDA Number, whether the award is R&D, the total amount of the award, and the period of performance. While the Corporation did not perform a risk assessment of each subrecipient, it reviewed all requests for reimbursement to ensure there was adequate support and that the activity was allowable and consistent with the terms and conditions of the grant. Cause and Effect - The Corporation did not review the requirements of 2 CFR 200.331 to ensure agreements were in compliance with the Uniform Guidance. Without providing the necessary information to subrecipients and the lack of risk assessments, subrecipients are at a greater risk of noncompliance, which can result in noncompliance and questioned costs for the Corporation. Recommendation - The Corporation should implement a process to ensure subrecipient agreements and/or the documentation provided to subrecipients aligns with the requirements in 2 CFR Section 200.331(a)(1). Additionally, the Corporation should document risk assessments and monitoring procedures completed on subrecipients in accordance with 2 CFR Section 200.331(b) and 2 CFR Section 200.331(d). Views of Responsible Officials and Planned Corrective Actions - The SPO office will follow guidelines put into place to ensure that subaward agreements have all the required information and that documentation is obtained for all subaward monitoring.
Finding Number: 2020-002 Condition: The Corporation did not include all of the required information within the subrecipient agreements, nor did the Corporation evaluate its subrecipients? risk for noncompliance. Planned Corrective Action: We acknowledge that the subrecipient agreements did not include all required information required under 2 CFR 200.331 section A. We reviewed the requirements and determined the below requirements need to be added to the subrecipient agreements. ? 1.iv ? federal award date of award to the recipient ? 1.xi - CFDA number and name ? 1.xii - Identification on whether the award is R&D The current subrecipient agreements have been updated to include this required information and amendments have been processed and executed. We acknowledge that we did not adequately document the subrecipients for noncompliance. The program director was conducting monthly calls with subrecipients in regards to grant milestones and program progress however, there was no specific agenda in place nor proper documentation in regards to the work being completed. We are have set up strict guidelines for subrecipient monitoring so this does not occur in the future. Monitoring will occur at least quarterly by the grant program director as well as the grants consultant to ensure subrecipient is meeting all grant requirements. The monitoring guidelines will dictate how these monitoring visits should occur and what documentation is required. Once the monitoring visit has occurred, documentation will be reviewed by the grants consultant and signed off by the OhioHealth Research Institute Sponsored Program Office Director. Financially, the grants consultant will ensure subrecipient invoices include appropriate line items that match the sub award budget to ensure the spending is occurring in the correct areas, this includes the general ledger lines. Furthermore, line item expense totals will be tracked using internal reconciliation tracking sheets to track the subrecipient?s spending over the life of the prime grant. This will also ensure that no line item gets overspent. We implemented an audit certification request for subrecipients so they can provide the audit reporting package or written notification of compliance with the Uniform Guidance audit requirements. This request will go out to subrecipients once a year. We have developed a subrecipient checklist with all sub-award requirement to ensure that this situation does not occur in the future. Sub-award agreements were updated to include all of the corrected info in the year 5 agreements as these were being set up at this time. For DYFY, the year 5 agreement was initially routed for signatures however the R&D stats was incorrectly listed as no. This was updated and re-routed for signatures. The agreement was executed on September 8, 2020 due to the delay in the doc getting updated. For the NCH, the year 5 agreement was updated and was executed on September 15, 2020. For sub-recipient invoices, the grants coordinator worked with the fiscal contacts at the sites to ensure all the appropriate backup info is included. All invoices after August 31, 2020 have the required backup information; however, the grants coordinator was working with the sites prior to this time and a number of invoices prior to August 31, 2020 had the required info. While prior to this finding, sub-recipient meetings occurred either monthly or quarterly, we did not have a formal tracking / minutes for the meetings. This process has been implemented and meeting minutes are now completed for each meeting. The sub checklist has been completed and will be utilized for future new sub-recipient requests to ensure that all requirements are met. Contact Person Responsible for Corrective Action: Michael Brechbuhler Anticipated Completion Date: September 15, 2020
2019-002
CFDA Number, Federal Agency, and Program Name - CFDA #16.575, U.S. Department of Justice, Crime Victim Assistance Federal Award Identification Number and Year - 2019 VOCA 132181783, 2019 VOCA 132136354, 2019 SVAA 132181788 Pass through Entity - Ohio Attorney General Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes, 2019 003 Criteria - Per 2 CFR 200.318(a) The nonfederal entity must use its own documented procurement procedures, which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part. In addition, the entity must have procedures in place to ensure that vendors are not suspended, debarred, or otherwise excluded from participating in federally funded programs under 2 CFR Section 200.213. Condition - Controls in place did not ensure that the Corporation followed its federal award contracting and purchasing policy for contracts in excess of its micropurchase threshold. Questioned Costs - $94,651 Identification of How Questioned Costs Were Computed - The amount represents the total expenditures of four vendors whose contracts were not procured consistent with the Corporation's federal award contracting and purchasing policy. Context - For 9 out of the 60 procurement transactions tested, the Corporation did not procure the goods/services consistent with its procurement policy, specifically the small purchase procedures or the procurement by sealed bids (formal advertising). Cause and Effect - The Corporation did not follow its federal award contracting and purchasing policy. This resulted in an inability of the Corporation to provide evidence that the procurement transaction was conducted in a manner providing full and open competition, which resulted in questioned costs. If procurement procedures are not followed, it could result in the grant incurring unreasonable costs due to competition being limited. In addition, grant funded contracts could be awarded to vendors that are suspended or debarred. Recommendation - The Corporation should ensure all personnel are aware of its federal award contracting and purchasing policy and that it is followed for all federally funded procurement transactions. Views of Responsible Officials and Planned Corrective Actions - The SPO team will continue to work closely with procurement to ensure that all processes are followed to ensure adherence to proper controls.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - CFDA #16.575, U.S. Department of Justice, Crime Victim Assistance Federal Award Identification Number and Year - 2019 VOCA 132181783, 2019 VOCA 132136354, 2019 SVAA 132181788 Pass through Entity - Ohio Attorney General Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes, 2019 003 Criteria - Per 2 CFR 200.318(a) The nonfederal entity must use its own documented procurement procedures, which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in this part. In addition, the entity must have procedures in place to ensure that vendors are not suspended, debarred, or otherwise excluded from participating in federally funded programs under 2 CFR Section 200.213. Condition - Controls in place did not ensure that the Corporation followed its federal award contracting and purchasing policy for contracts in excess of its micropurchase threshold. Questioned Costs - $94,651 Identification of How Questioned Costs Were Computed - The amount represents the total expenditures of four vendors whose contracts were not procured consistent with the Corporation's federal award contracting and purchasing policy. Context - For 9 out of the 60 procurement transactions tested, the Corporation did not procure the goods/services consistent with its procurement policy, specifically the small purchase procedures or the procurement by sealed bids (formal advertising). Cause and Effect - The Corporation did not follow its federal award contracting and purchasing policy. This resulted in an inability of the Corporation to provide evidence that the procurement transaction was conducted in a manner providing full and open competition, which resulted in questioned costs. If procurement procedures are not followed, it could result in the grant incurring unreasonable costs due to competition being limited. In addition, grant funded contracts could be awarded to vendors that are suspended or debarred. Recommendation - The Corporation should ensure all personnel are aware of its federal award contracting and purchasing policy and that it is followed for all federally funded procurement transactions. Views of Responsible Officials and Planned Corrective Actions - The SPO team will continue to work closely with procurement to ensure that all processes are followed to ensure adherence to proper controls.
Finding Number: 2020-003 Condition: Controls in place did not ensure that the Corporation followed its federal award contracting and purchasing policy for contracts in excess of its micropurchase threshold. Planned Corrective Action: Controls in place did not ensure that OhioHealth followed its federal award contracting and purchasing policy for contracts in excess of its micro-purchase threshold. Planned corrective action: We acknowledge the lack of internal controls to ensure the federal award contracting and purchasing policy was being followed for all federal purchases over the micro-purchase threshold. The lack of controls were due to a lack of understanding of the purchase requirements as pertaining to both the federal and Corporate policy as well as assignment of responsibilities. The purchases in question utilized approved OhioHealth vendors that followed Corporate policies however did not specifically meet the federal policy. We have worked with the procurement team to review the federal procurement process to allow for better controls and ownership of individual processes. The grants consultant will ensure that when submitting purchases over the micro-purchase threshold, the request is clearly communicated to the correct procurement team that the purchase is for a federal grant and specific processes need to be followed. The grant consultant will then work with procurement to get the required bidding request / documentation required for the grant. After this process has occurred, the PO will be generate and the order processed. This process will be followed for each grant fiscal year for purchases over the micro-purchase threshold. As stated above, a process was outlined with the procurement team to allow for the required processes that are required for purchases over the micro-purchase threshold. We are also in the process of updating our Federal Award Purchasing Policy to increase the micro-purchase threshold from $3k to $10k based on the updated guidance. For expenditures on grants during fiscal year 2021 that were over micro-purchase threshold, in all cases, the grant consultant submitted a written request to the Federal Awarding agency or pass-through entity to authorize the use of the vendor. In all cases, the agency approved the vendor. This approval was received before the expenditure occurred. Contact Person Responsible for Corrective Action: Michael Brechbuhler Anticipated Completion Date: August 31, 2020
2019-003
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