Kennedy Krieger InstituteNon-Profit

During fiscal year 2025, Kennedy Krieger Institute identified a control weakness with our established FFATA reporting control. After thorough review of active subaward agreements, Kennedy Krieger Institute identified two contracts that were not reported timely as the projects were not centrally managed and therefore fell outside of its normal research administration process. Upon identification, Kennedy Krieger Institute promptly submitted the FFATA reports via SAM.gov. Kennedy Krieger Institute has since enhanced its FFATA reporting control through strengthened governance, system improvements, and expanded oversight. As part of the Institute’s Subaward Management processes, the FFATA reporting process has been clearly defined and communicated to all grant managers, ensuring that all subawards are maintained within a centralized sponsored projects reporting system (Fibi), regardless of the team responsible for award management. Fibi has been updated to include a required checkbox and date field indicating when FFATA reporting has been completed and the associated submission date. In addition, Kennedy Krieger Institute is working with system developers to implement a standard system-generated report that can be run monthly or on an ad hoc basis to identify all subawards subject to FFATA reporting, enabling Finance to validate completeness and timeliness across all areas. Finance will complete regular checks of subawards set up in the financial system of record in comparison to Fibi to ensure all subawards are being reported timely. These enhancements establish a checks and balances framework through clearly defined shared responsibilities and coordinated oversight between the Research Administration and Finance departments. This control enhancement was implemented for the January 2026 FFATA reporting cycle.

During the fiscal year ended June 30, 2024, Kennedy Krieger Institute maintained a policy to ensure supply, equipment and professional service vendors that are charged to Federal awards were not suspended or debarred from doing business with the Federal government. The policy involves confirming through the System for Award Management (SAM) whether the vendor was excluded due to suspension or debarment. (1) New vendors are verified in SAM as the vendors ae established in our vendor master file prior to payment. Required documentation is maintained as support. (2) Existing vendors are verified throughout the fiscal year, but at least annually. This allows adequate time to cost transfer any excluded vendors prior to closing out an award. The last verification was performed in December and was fully documented. While we agree with the finding 2024-001, we note that our corrected action plan was not put into place until February 2024, more than mid-way through our fiscal year 2024. We performed retroactive verification of all impacted vendors and found no excluded vendors in SAM. We believe the modification to our procurement policy surrounding vendors made in February of 2024 and the mitigation measures used for fiscal year 2024, will ensure compliance with 2 CFR Section 180.220.

2023-001

During the fiscal year ended June 30, 2023 Kennedy Krieger Institute maintained a policy of checking the System for Award Management (SAM) for vendors as follows: (1) New vendors as the vendors are established in our vendor master file prior to payment; and (2) Existing vendors on an annual basis, the last checks performed in September 2022 and December 2023. We agree with the finding 2023-001 noted with in the report. In response to this finding, we have amended our procurement policy to ensure the required documentation is maintained simultaneously with the vendor checks to verify the checks are completed prior to contracting with and paying a vendor. For contracts and payments to vendors where the purchase amount is for $25,000 or more and are to be funded from a government grant or sponsored source, the required documentation will be retained to assure vendor check through SAM are being made prior to contracting with such vendor or before payment to the vendor.. Due to the timing of implementing this policy amendment, we will review FY 2024 activity to ensure all vendors have evidence of documentation of vendor checks. We believe these modifications to our vendor procurement policy and the mitigation measure for fiscal year 2024, will ensure compliance with 2 CFR Section 180.220.

In attesting to the methodology used to calculate lost revenue in accordance with the June 11, 2021 General and Targeted Distribution Post-Payment Notice of Reporting Requirements, Option (i) difference between actual patient care revenues was selected in the HRSA reporting portal. Differences in actual patient care revenues were used in both the base and target periods, however, we made a modification to what was included in patient care revenue and only included those revenues generated through inpatient services and excluded patient care revenue generated from outpatient services. The rationale for including inpatient revenue and excluding outpatient revenue is detailed below. The pandemic impacted patient service revenue on the inpatient units by contributing to lower inpatient census for a variety of reasons. These reasons include mandatory infection control, patient distancing an isolation requirements and severe staffing shortages. All of our semiprivate and other multi-patient rooms were converted to private rooms to limit patient contact with other patients and their families during admission. Additionally, we only permitted patient admissions from Maryland and our neighboring states (State mandates), thereby limiting the patient admission pool. Last, the pandemic created severe staffing shortages in nursing, therapy and clinical aids thereby requiring reduced admissions for patient safety reasons. The shortages occurred due staff COVID infection, exposure, isolation and other limitations on their ability to perform their jobs. These factors drove down inpatient admissions, patient days and the related patient service revenue levels as compared to pre-pandemic levels. At the outset of the pandemic, outpatient operations were essentially shut down with very few patients seen. However, within 2 to 4 weeks from pandemic outset, we were able to effectively pivot operations from a completely on-site operation to providing services to more than 20,000 outpatient visits through tele-health. Using tele-health, patients were able to see their clinical providers from their home via a Zoom link. Same was true for the clinical providers. The quick transition to tele-health really limited the impact that the pandemic had on outpatient operations and specifically limited lost revenue to only a couple weeks. The quick change in the method of care delivery between on-site services and services rendered by telehealth had a significant impact on provider productivity and the type of revenue recognized. It was determined that these differences did not allow for an accurate apples to apples comparison of patient service revenue pre-pandemic versus during the pandemic. We concur with the finding that Option (iii) should have been selected as the methodology used in determining lost revenue for Provider Relief Fund reporting. We plan to make the necessary corrections to the change in methodology for period 1 & 2 reporting while submitting our period 4 reporting by March 31. 2023. HRSA was contacted before September 30, 2022 and we were instructed that any changes in methodology would need to be made during our next open reporting period. This window has just opened on January 1, 2023 and corrections will be made for this reporting methodology by March 31, 2023. We plan to make the necessary corrections to the change in methodology for period 1 & 2 reporting while submitting our period 4 reporting by March 31. 2023.

2021-001

In attesting to the methodology used to calculate lost revenue in accordance with the June 11, 2021 General and Targeted Distribution Post-Payment Notice of Reporting Requirements, Option (i) difference between actual patient care revenues was selected in the HRSA reporting portal. Differences in actual patient care revenues were used in both the base and target periods, however, we made a modification to what was included in patient care revenue and only included those revenues generated through inpatient services and excluded patient care revenue generated from outpatient services. The rationale for including inpatient revenue and excluding outpatient revenue is detailed below. The pandemic impacted patient service revenue on the inpatient units by contributing to lower inpatient census for a variety of reasons. These reasons include mandatory infection control, patient distancing an isolation requirements and severe staffing shortages. All of our semiprivate and other multi-patient rooms were converted to private rooms to limit patient contact with other patients and their families during admission. Additionally, we only permitted patient admissions from Maryland and our neighboring states (State mandates), thereby limiting the patient admission pool. Last, the pandemic created severe staffing shortages in nursing, therapy and clinical aids thereby requiring reduced admissions for patient safety reasons. The shortages occurred due staff COVID infection, exposure, isolation and other limitations on their ability to perform their jobs. These factors drove down inpatient admissions, patient days and the related patient service revenue levels as compared to pre-pandemic levels. At the outset of the pandemic, outpatient operations were essentially shut down with very few patients seen. However, within 2 to 4 weeks from pandemic outset, we were able to effectively pivot operations from a completely on-site operation to providing services to more than 20,000 outpatient visits through tele-health. Using tele-health, patients were able to see their clinical providers from their home via a Zoom link. Same was true for the clinical providers. The quick transition to tele-health really limited the impact that the pandemic had on outpatient operations and specifically limited lost revenue to only a couple weeks. The quick change in the method of care delivery between on-site services and services rendered by telehealth had a significant impact on provider productivity and the type of revenue recognized. It was determined that these differences did not allow for an accurate apples to apples comparison of patient service revenue pre-pandemic versus during the pandemic. We concur with the finding that Option (iii) should have been selected as the methodology used in determining lost revenue for Provider Relief Fund reporting. We plan to contact HRSA by September 30, 2022 to determine if there are any required corrections to the previous reporting portal submissions

GSA_MIGRATION

2016-001