EIN: 550377012
UEI: HN8ATK8SRHJ3
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 15, 2020. 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 April 15, 2021 (1958 days ago).
What is a management decision? →During a review by the West Virginia Department of Health & Human Resources (?WVDHHR?) monitoring and compliance division, as pass through awarding agency, it was noted that Health Education Foundation of West Virginia, Inc. (?HEF?), an affiliate of the West Virginia Hospital Association (?WVHA?), charged contractual expenses to federal grants but had only a memorandum of understanding between WVHA and HEF for WVHA employees to support the contractual expenditures. For a portion of the period under audit through October 2019, HEF had no employees making it a fiscal agent. HEF was receiving the federal funds and was utilizing WVHA employees to provide certain services such as technical support, consulting, etc. under the grant agreements. There were no formal contracts in place related to the work performed for HEF by WVHA employees until October 2019, when corrective action was taken. Questioned Costs: None Context: Contractual expenses charged to federal award programs for services provided by WVHA for the year ended December 31, 2019, were approximately $242,000 through October 2019, when corrective action was taken. Cause: Management indicated that it was their historical understanding that a memorandum of understanding between WVHA and HEF was sufficient to charge contractual expenses to the grants, based on previous discussions with the grantor pass through agency. Effect: Without formal contractual arrangements in place, the contractual expenses charged to grants could be deemed unallowable. Recommendation: In conjunction with the 2018 Single Audit, we recommended that management develop and place into effect policies, procedures and controls to ensure that formal legal contracts are in place to support contractual services charged to grants. Furthermore, we recommended that WVHA should maintain written standards of conduct covering organizational conflicts of interest. Corrective action was implemented by management in October 2019.
Show full finding ▾Hide full finding ▴Criteria: 2 CFR section 200.22 defines a contract as, ?a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this part does not include a legal instrument, even if the non-Federal entity considers it a contract when the substance of the transaction meets the definition of a Federal award or subaward.? The 2 CFR section 200.23 defines a contractor as ?an entity that receives a contract as defined in ?200.22 Contract.? In accordance with general procurement standards at 2 CFR section 200.318, if the non-Federal entity has a parent, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, the non-Federal entity must also maintain written standards of conduct covering organizational conflicts of interest. Organizational conflicts of interest means that because of relationships with a parent company, affiliate, or subsidiary organization, the non-Federal entity is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. Condition: During a review by the West Virginia Department of Health & Human Resources (?WVDHHR?) monitoring and compliance division, as pass through awarding agency, it was noted that Health Education Foundation of West Virginia, Inc. (?HEF?), an affiliate of the West Virginia Hospital Association (?WVHA?), charged contractual expenses to federal grants but had only a memorandum of understanding between WVHA and HEF for WVHA employees to support the contractual expenditures. For a portion of the period under audit through October 2019, HEF had no employees making it a fiscal agent. HEF was receiving the federal funds and was utilizing WVHA employees to provide certain services such as technical support, consulting, etc. under the grant agreements. There were no formal contracts in place related to the work performed for HEF by WVHA employees until October 2019, when corrective action was taken. Questioned Costs: None Context: Contractual expenses charged to federal award programs for services provided by WVHA for the year ended December 31, 2019, were approximately $242,000 through October 2019, when corrective action was taken. Cause: Management indicated that it was their historical understanding that a memorandum of understanding between WVHA and HEF was sufficient to charge contractual expenses to the grants, based on previous discussions with the grantor pass through agency. Effect: Without formal contractual arrangements in place, the contractual expenses charged to grants could be deemed unallowable. Recommendation: In conjunction with the 2018 Single Audit, we recommended that management develop and place into effect policies, procedures and controls to ensure that formal legal contracts are in place to support contractual services charged to grants. Furthermore, we recommended that WVHA should maintain written standards of conduct covering organizational conflicts of interest. Corrective action was implemented by management in October 2019.
Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. We have submitted our corrective action plan in response to the review by the WVDHHR in October 2019, which included the following. a) Submitted a certification letter to the WVDHHR that all grant monies were expended to achieve the goals and objectives of each grant respectively, and that the goals and objective for each grant were satisfied completely. b) Submitted certification letter to the WVDHHR stating that the HEF maintains and complies with current written procurement procedures entitled ?Healthcare Education Foundation of West Virginia, Inc.?s Uniform Guidance Procurement Standards Compliance Policy? in accordance with the requirements of 2CFR 200.318 (?General procurement standards?) through 2CFR 200.326 (?Contract provisions?). c) Certain employees of WVHA became employees of HEF in October 2019. Thus, HEF is no longer a fiscal agent. Additionally, HEF now maintains written standards of conduct covering organizational conflicts of interest. We received acknowledgement from WVDHHR that our corrective action plan was accepted and that no further actions are required at this time.
2018-001
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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