League for Innovation in the Community College

U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Procurement Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. The Organization is required to create a written procurement, suspension, and debarment policy that complies with applicable federal requirements and to follow this policy when procuring goods and services. The Organization is also required to retain documentation supporting performance of a price analysis and open competition. Condition: The Organization’s procurement policy does not contain all provisions required by Appendix II to 2 CFR Part 200. Additionally, there was no documentation retained supporting a price analysis over the transactions tested. Cause: The Organization has limited staffing and did not have proper controls in place relating to review of the procurement policy. Effect: The Organization did not ensure that the procurement policy was complete and accurate. Questioned Costs: None reported. Context: A nonstatistical sample of 4 out of 9 procurement transactions were selected for testing, which accounted for $175,792 of $370,234 qualified expenditures.Repeat Finding from Prior Years: No Recommendation: We recommend the Organization follow control processes implemented which includes updating the procurement policy and documenting the performance of required procurement procedures. Views of Responsible Officials: Management agrees with the finding.

U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Activities Allowed or Unallowed, Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Criteria: As per 2 CFR section 200, a complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition: The Organization did not maintain documentation for the proper review and approval of expenditures for all expenditures. Cause: The Organization has limited staffing and did not have proper controls in place relating to review and approval of expenditures. Effect: Improper expenses may be paid and charged to the federal program or charged/released at the wrong amount. Questioned Costs: None reported. Context: A nonstatistical sample of 60 transactions out of 250+ total transactions were selected for testing direct costs, which accounted for $508,488 of $1,049,535 direct costs. There was no support for review and approval for 11 of the 60 tested. A nonstatistical sample of 4 out of 12 total monthly indirect calculations were selected for testing indirect costs, which accounted for $17,667 of $46,613 indirect costs. All 4 calculations did not have support for the review and approval. Repeat Finding from Prior Years: No Recommendation: We recommend the Organization implement a control process which includes a review and approval of expenditures. Views of Responsible Officials: Management agrees with the finding.

U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Uniform Guidance section 200.332 requires that pass‐ through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients. It also requires that pass‐through entities 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. Condition: The Organization did not provide all required provisions on the subrecipient agreements. Additionally, the Organization was not reviewing audit requirements. Cause: The Organization has not properly reviewed requirements relating to subrecipients. Effect: Incomplete contract agreements with subrecipients could be entered into and/or there could be ineffective monitoring. Questioned Costs: None reported. Context: A nonstatistical sample of 9 transactions of 49 were selected for testing of subrecipient monitoring, which accounted for $141,611 of $583,403 of subrecipient monitoring expenditures. Repeat Finding from Prior Years: No Recommendation: We recommend the Organization ensure proper documentation is maintained on contract agreements with subrecipients. Views of Responsible Officials: Management agrees with the finding.

Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Reporting Material Weakness in Internal Control over Compliance Criteria: A complete system of internal controls requires all reports submitted be properly approved and supported by appropriate documentation. Condition: Uniform Guidance section 200 provides that records supporting internal control activities be maintained. The Organization did not maintain documentation for the proper review and approval of reports prior to submission. Cause: The Organization has limited staffing and did not have proper controls in place relating to review and approval of reports. Effect: Inaccuracies in reports submitted could occur without proper review procedures. Questioned Costs: None reported. Context: A nonstatistical sample of 4 reports out of 12 total reports were selected for testing. Repeat Finding from Prior Years: No Recommendation: We recommend the Organization implement a control process which includes a review and approval of reports. Views of Responsible Officials: Management agrees with the finding.

U.S. Department of Health and Human Services Passed through Health Research & Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Preparation of Schedule of Expenditures of Federal Awards Material Weakness in Internal Control over Compliance Criteria: Proper controls over financial reporting include the ability to prepare the schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Condition: The Organization does not have an internal control system designed to provide for the preparation of the Schedule.Cause: The Organization has limited staffing and did not have proper controls in place relating to the Schedule. Effect: There is a reasonable possibility that the Organization would not be able to draft the Schedule that is correct without the assistance of auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: No Recommendation: While we recognized that this condition is not unusual for an organization with limited staffing, we recommend management be aware of the financial reporting requirements relating to the Organization’s schedule of expenditures of federal awards and the internal controls that impact financial reporting. Views of Responsible Officials: Management agrees with the finding.