EIN: 460902111
UEI: JD8DPSN9GGG5
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 1, 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 May 1, 2025, which was (476 days ago).
What is a management decision? →Finding 2023-001: Segregation of Duties Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment. Statement of Condition: RTOG Foundation, Inc. (Foundation) does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. During 2023, the project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation. Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred. Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-001 – Segregation of Duties Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which is reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor. Management Response: In August of 2022, the RTOG Foundation Inc. executed a Financial Management Services Agreement with the NSABP Foundation Inc. to provide oversight and management of financial statement preparation. The independent resources provided under this contract include day to day financial support from a Director of Finance with a supporting staff of accountants, financial analysts, and top-level oversight by a Senior Director of Finance with extensive experience in the financial management of clinical trials. The prior project manager referenced above has relinquished all financial accounting responsibilities and appropriate segregation of duties has been achieved, including, but not limited to, internal controls surrounding the payment of invoices. Routine financial analysis, account reconciliations, treasury functions, audit support and budgeting are also included under this services agreement. Monthly financial results are reviewed with the Board of Directors at regularly scheduled meetings.
2022-001
Finding 2023-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2023-002 - Department of Health and Human Services – Research & Development Cluster- Subrecipient Monitoring Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Management Response: The RTOG Foundation Inc. has adopted the subrecipient monitoring policy of NRG Oncology that comports with the “Subrecipient Compliance With Uniform Administrative Requirements, Cost Principles, and Audit Requirements.” Additionally, activity of subrecipients of the Foundation, including the American College of Radiology (ACR) is monitored under the Management Services Agreement with the NSABP Foundation, via routine analysis and documentation of ongoing activities as well as inspection of ACR financial statements to ensure compliance with 2 CFR 200.322. Lastly, RTOG has created an SOP and document templates to assist in the monitoring of subrecipients.
2022-002
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 8, 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 October 8, 2024, which was (681 days ago).
What is a management decision? →Finding 2022-001: Segregation of Duties Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment. Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation. Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001 – Segregation of Duties Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which is reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor. Management Response: In August of 2022, the RTOG Foundation Inc. executed a Financial Management Services Agreement with the NSABP Foundation Inc. to provide oversight and management of financial statement preparation. The independent resources provided under this contract include day to day financial support from a Director of Finance with a supporting staff of accountants, financial analysts, and top-level oversight by a Senior Director of Finance with extensive experience in the financial management of clinical trials. The prior project manager referenced above has relinquished all financial accounting responsibilities and appropriate segregation of duties has been achieved, including, but not limited to, internal controls surrounding the payment of invoices. Routine financial analysis, account reconciliations, treasury functions, audit support and budgeting are also included under this services agreement. Monthly financial results are reviewed with the Board of Directors at regularly scheduled meetings.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary. Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients. Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective. Questioned Costs: None. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332. Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002 - Department of Health and Human Services – Research & Development Cluster- Subrecipient Monitoring Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient. Management Response: The RTOG Foundation Inc. currently utilizes a standard form “Subrecipient’s Compliance With Uniform Administrative Requirements, Cost Principles, and Audit Requirements For Federal Awards, Subpart F” with all federally-funded grants and cooperative agreements subject to the Uniform Guidance. Additionally, activity of the sole subrecipient of the Foundation, the American College of Radiology (ACR) is monitored under the Management Services Agreement with the NSABP Foundation Inc., via routine analysis and documentation of ongoing activities as well as the inspection of ACR financial statements to ensure compliance with 2 CFR 200.332.
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