Open Recommendations

Direct Columbia to strengthen its internal controls and processes for obtaining NSF approval for subawards. This could include:
• Requiring Sponsored Projects Administration to verify whether a subaward is explicitly identified within the award budget approved by NSF or written approval is obtained from the NSF Grants Officer before establishing the subaward.
• Requiring periodic training for Principal Investigators and other personnel responsible for identifying subaward agreements under NSF awards.

Direct Columbia to strengthen its procedures and internal controls around invoice processing to ensure duplicate payments are not made to subawardees.

Direct Columbia to provide documentation supporting it has repaid or otherwise credited the $9,441 in questioned indirect cost expenses for which it has agreed to reimburse NSF.

Direct Columbia to strengthen its policies, procedures, and internal control processes for ensuring its subawardees appropriately apply either their federally negotiated indirect cost rates or the de minimis rate to NSF awards. These updated procedures could include:
• Requiring personnel responsible for approving invoices to perform a calculation in order to determine whether the indirect costs invoiced are appropriate based on the direct costs invoiced and the rate identified in the subawardee’s Negotiated Indirect Cost Rate Agreement (or the de minimis rate when the subawardee does not have a federally negotiated rate).
• Developing resources that provide guidance on appropriately…

Direct Columbia to strengthen its subaward monitoring procedures to ensure that it verifies whether its subawardees apply the appropriate fringe benefit rates included within their Negotiated Indirect Cost Rate Agreements.

Direct Columbia to establish and implement policies and procedures or internal controls for executing subaward modifications to extend the subaward period of performance prior to paying invoices under an expired subaward.

Direct Columbia to develop resources that provide its subawardees with guidance on how to perform—and document performance of—risk assessments prior to issuing subawards.

Direct Columbia to develop resources that provide its subawardees with guidance on the types of policies and procedures and financial accounting system records necessary to demonstrate compliance with federal financial management systems requirements.

Direct Columbia to establish and implement policies and procedures or internal controls for ensuring that invoices are processed and paid within the 30-day time limit.

Direct Columbia to update its invoice review procedures to ensure that subawardee invoices include all of the data elements required per the subaward terms and conditions.

Direct Columbia to develop additional resources for subawardees that provide guidance on how to ensure they appropriately account for and invoice expenses on a cost-reimbursement basis consistent with subaward terms and conditions.

Direct Columbia to implement additional policies or procedures to ensure that subawardees complete and submit any progress, technical, or other reports that Columbia requires per the subaward terms and conditions.

Direct Columbia to implement internal controls to ensure that all required subawardee documentation is appropriately completed and provided to Columbia’s Sponsored Projects Administration prior to subaward issuance.

Direct Columbia to implement internal controls to ensure that Principal Investigators review and approve invoices—and document this approval—within the time limit defined in its policy.

Direct Columbia to implement internal controls to ensure that International Risk Questionnaires are appropriately completed and provided to Columbia’s Sponsored Projects Administration prior to subaward issuance.

We recommend that USAID/Kenya and East Africa verify that Strathmore University corrects the two instances of material noncompliance identified on pages 36, 38 to 42 of the audit report.

We recommend that USAID/Democratic Republic of the Congo verify that Humana People to People Congo Asbl corrects the two instances of material noncompliance identified on pages 34, 35 to 37 of the audit report.

We recommend that USAID/Ethiopia verify that Mekdim Ethiopia National Association corrects the three instances of material noncompliance detailed on pages 35 to 38 of the audit report.

We recommend that the West Virginia Bureau for Medical Services refund to the Federal Government $2,159,071 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the West Virginia Bureau for Medical Services refund to the Federal Government $14,514 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the West Virginia Bureau for Medical Services work with CMS to determine the unallowable portion of $488,185 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable.

We recommend that the West Virginia Bureau for Medical Services strengthen internal controls for non-crossover claims going forward, to better use collected data to invoice manufacturers and collect rebates for all eligible physician-administered drugs.

We recommend that the West Virginia Bureau for Medical Services consider revising its payment methodology going forward regarding payments for crossover claims, thereby allowing collection of manufacturers' rebates for associated physician-administered drugs.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to do the following: Recover $11,399 in overpayments made to suppliers for the 15 sample items that did not meet Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to do the following: Perform additional medical reviews of claims for intermittent urinary catheters and sterile catheter kits, which could have saved Medicare an estimated $35,079,833 for our audit period.