UPDATE from OIG

 The opinions expressed today are those of the speaker and not necessarily the opinions of the Department of Health and Human Services (HHS), Office of Inspector General (OIG)

OAS Workload Audit Process Work Plan for Colleges and Universities OMB Uniform Guidance Presence of OIG in Educational Institutions

Daniel R. Levinson, Inspector General Mission - To protect the integrity of Department of Health & Human Services (HHS) programs as well as the health and welfare of program beneficiaries.

 Established  Largest Inspector General's office in the Federal Government – approximately 1750 employees  OIG's oversight:  All programs under other HHS institutions including CMS, CDC, NIH, FDA,ACF, HRSA.

 Conduct independent audits of HHS programs and/or HHS grantees and contractors.  Provide assistance in criminal, civil, and administrative investigations.  Oversee HHS's annual financial statement audits. Gloria Jarmon– Deputy Inspector General for Audit Services

WASHINGTON MONTANA WYOMING UTAH COLORADO OREGON CALIFORNIA ARIZONA NEW MEXICO TEXAS OKLAHOMA KANSAS MISSOURI MS. KENT AK OAS Regional Boundaries Boston Region – I New York Region – II Philadelphia Region – III Atlanta Region – IV Chicago Region – V Dallas Region – VI Kansas City Region – VII San Francisco Region - IX Headquarters Offices Regional Offices Field Offices PUERTO RICO TX NM AZ CA NV UT CO KS OK LA AR MO IA MN NE WY SD OR WA ID MT ND WI IL IN OH KY TN WV PA VA MI NY VT NH MA DE ME NC SC GA AL MS FL NJ MD CT RI DC HI

 Workload is related to funding  80% Health Care (Medicare & Medicaid)  20% Discretionary (Everything else including college & universities)  We do Performance and Cost Audits

 Medicaid Dental  Head Start Health & Safety  Select Agents PERFORMANCE AUDITS

 Bid Proposals  Grant/Contract Closeouts  Recipient Capability Audits  Requested Audit Services COST AUDITS

OIG.HHS.GOV

 OMB Circular A-133 established cognizance  Designated which Federal agency has primary responsibility for audit of all Federal funds received by an entity.  HHS OIG holds audit cognizance over all State governments and most major research colleges and universities.  HHS OIG receives reimbursement for audits that it performs on non-HHS funds.

 Audits may be requested by Congress, HHS, and other Federal organizations.  Requested audit services include:  Contract and grant closeouts;  Bid Proposals;  Other reviews designed to provide specific information requested by management.

Planning  Identify Issue or Concern  Identify Staff  Team Meeting  Identify Audit Requirements  Identify type of Audit  Contact Auditee  Review of Criteria  Meeting with Program Officials

Survey  Focus Objectives and Identify Subobjectives  Survey plan  Coordinate with Other Auditors  Preliminary Review and Analysis  Team Meeting  Go/No-Go  Audit program  Audit leads

Data Collection and Analysis  Evidence  Physical  Documentary  Testimonial  Analytical  Audit Documentation

Reporting  Team meeting  Writing the Draft Report  Independent Report Review  Issuing the Draft Report  Issuing the Final report

Draft Report: OIG issues to auditee. 30- day comment period. OIG receives comments, incorporates into report, and addresses them in the report. OIG issues final report, with auditee comments summarized & OIG response included. Appendix has auditee’s full comments. OIG tracks report recommendations for resolution; awaits clearance from cognizant OPDIV.

 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards  2 CFR Chapter I, and Chapter II, Parts 200, 215, 220, 225, and 230  Effective December 26, 2014

 Section Compensation—Personal Services  Strengthens the requirements for non-Federal entities to maintain high standards for internal controls over salaries and wages while allowing for additional flexibility  Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed

 No longer any specific requirements for after- the-fact certifications or plan-confirmation systems  Systems still need to accurately reflect work performed  Budget estimates can not be used unless there are procedures to update significant budget changes  The Federal Demonstration Partnership (FDP) is piloting a payroll certification system in lieu of effort reporting

 University of California, San Diego – Audit report issued in April 2015  $202,401 in unallowable administrative costs that were directly charged to projects  University of Louisville – Ongoing  Reviewing administrative costs

 Reviews of the FDP’s Pilot Payroll Certification System  Joint reviews between the HHS OIG and the National Science Foundation OIG at: ▪ George Mason University (Audit Report Issued) ▪ University of California – Irvine (Audit Report Issued) ▪ University of California – Riverside (Ongoing) ▪ Michigan Technology University (Audit Report Issued )

 George Mason University – Audit Report issued July 31, 2015  $746,229 in costs that were not adequately documented because the University did not always comply with its documentation policies for payroll ▪ Timeliness of certifications, cost transfers, time sheet reviews, and bimonthly certifications  There were also access control issues related to its payroll computer system ▪ Two factor authentication, old passwords, security patches

 University of California at Irvine – Audit Report issued December 31, 2014  We could not determine whether the payroll certification system provided data that supported labor charges because the University could not reconcile its accounting records to its Federal Financial Reports  A total variance of approximately $3.8 million for 666 Federal awards, totaling $491 million