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 2016 - 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- 1976

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

UTAHCOLORADO

OREGON

CALIFORNIA

ARIZONANEW MEXICO

TEXAS

OKLAHOMA

KANSASMISSOURI

MS.

KENT

AK

OAS Regional Boundaries

Boston Region – INew York Region – IIPhiladelphia Region – IIIAtlanta Region – IVChicago Region – VDallas Region – VIKansas City Region – VIISan Francisco Region - IX

Headquarters Offices

Regional Offices

Field Offices

PUERTO RICO

TX

NMAZ

CA

NV

UTCO

KS

OK

LA

AR

MO

IA

MN

NE

WY

SD

OR

WA

ID

MT ND

WI

ILIN

OH

KY

TN

WV

PA

VA

MINY

VTNH

MA

DE

ME

NC

SC

GAALMS

FL

NJ

MD

CTRI

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 StaffTeam Meeting Identify Audit Requirements Identify type of AuditContact AuditeeReview of CriteriaMeeting with Program Officials

Survey Focus Objectives and Identify

Subobjectives Survey planCoordinate with Other Auditors Preliminary Review and Analysis Team Meeting Go/No-Go Audit program Audit leads

Data Collection and AnalysisEvidence

Physical Documentary Testimonial Analytical

Audit Documentation

ReportingTeam meetingWriting 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.

http://oig.hhs.gov/

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 200.430 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