You are now demonstrating to the federal government that you do not have good internal controls in place and you are not able to fix the problem. If you keep making the same mistake and the auditor keeps having the same findings, it’s a serious red flag. You’ve demonstrated to your funding agency that you take your award seriously, want to be in compliance and will make the correction necessary. If you make the corrective action and there are no findings, great job. Next year, your UGA auditor will check to see if you’ve made the necessary changesĮach year, your auditor is required to look at the prior year’s findings, review your corrective action plan, and determine if you are now in compliance. If accepted, the findings must be fixed by the following year. When submitting their very thorough report, your auditor will detail everything that is wrong in a list format to the funding agency.Īt this point, you have the opportunity to come up with a corrective action plan, which you will need to submit to the agency. Partners Health had to defend themselves, explain their mistake and demonstrate procedures that would be in place to prevent these mistakes from ever happening again. The ramification is that these findings went into the UGA report, and the report went to every funding agency that gave this company a government award. A $100 flight upgrade that was charged to the award.īoth of those are unallowable expenses and resulted in audit findings.A $6.25 alcohol receipt that was charged to the award.That same year, during a UGA, their auditor reported two findings: In fact, in 2016, their total federal expenditures were $977,866,783. Partners HealthCare System Inc received a lot of government funding. A finding is a finding, no matter how large or small. It’s also important that you understand that there’s no materiality in findings. Managed your sub-contractors and consultants, ensuring that work performed and costs billed mirrors written agreements.Have not billed them when you exceed your provisional indirect cost rate.Can show that your draw down funds from the PMS or ASAP properly.Can produce accurate SF-425/FFR reporting.Maintain a thorough, accurate and auditable direct equipment inventory.Maintain a general ledger that matches the information in your time sheets.Keep accurate and compliant timekeeping and labor distribution procedures.Have defined, maintained and enforced internal controls in place.Comply with Agency Supplemental Regulations. That’s why they are going to make sure you: The government has invested in your innovation or research, and they want to make sure you are handling their funds correctly so that investment pays off. It’s important for you to understand that while a UGA can be intimidating, even nerve-wracking, it’s not a witch hunt. WHAT HAPPENS IF THERE’S A UNIFORM GUIDANCE AUDIT FINDING In this, our last blog, we’ll discuss what happens to NIH and DOE Grantees if there’s an audit finding. In our 7-part UGA series, we’ve explained the Uniform Guidance Audit, how it works, and how to avoid common findings.
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