Partial List of Recent Audits with Effort Reporting Findings

Transcription

1 Partial List f Recent Audits with Effrt Reprting Findings 12/09 Purdue University 12/09 Arizna State University 05/09 University f Delaware 04/09 Gergia Tech 04/09 University f Michigan 03/09 University f Arizna 03/07 University f Maryland Baltimre 03/07 Caltech 03/07 Gergia State University 09/06 University f Hawaii 05/06 University f Arizna 02/06 Yale 1/06 University f Cnnecticut 09/05 Dartmuth Center 08/05 UC Berkley 04/05 University f Alabama Birmingham 02/05 Flrida Internatinal University 08/04 East Carlina University 06/04 Harvard 03/04 Jhn Hpkins 06/03 Nrtheastern 02/03 Nrthwestern OIG HHS OIG HHS HHS HHS

2 Acrnym Key: : Department f Justice : Natinal Science Fundatin HHS: Health & Human Services OIG: Office f Inspectr General Effrt Audits & Summaries Harvard University ($2.4 Millin Settlement) Auditrs investigated 4 prjects that included expenses fr staff members wh did nt wrk n the prjects. $2.4 Millin Settlement Findings Faculty time was als fund t be verstated. Gvernment was billed fr salaries and expenses unrelated t federal grants. Harvard agreed t pay $3.3 millin ver charges a researcher spent fewer hurs than prmised n a research study. Jhns Hpkins University ($2.6 Millin Settlement) Auditrs investigated physicians wh received salaries frm the university as well as frm anther medical practice grup. Findings Faculty time and effrt devted t NIH grants was verstated. Knwingly verstated time wrked Charged mre than 100% f salary Prmised grant wuld supprt wrk by ther emplyees (but, the wrk was never perfrmed) Nrthwestern University ($5.5 millin, Settlement) Included time they spend treating patients. Auditrs investigated physicians wh charged grants fr time they spent treating patients. Researchers spent less time n NIH spnsred prjects than they reprted. Misrepresentatin f time spent

3 Failed t cmply with effrt reprting standards University f Cnnecticut ($2.5 Millin settlement) Auditrs investigated false claims in specialized service centers. Specialized Service Centers verstated anticipated expenses, vercharged the gvernment and billed fr items nt cvered by the grants. Billing Rates Failure t revise and apprpriately set its rate structure resulted in submissin f numerus false claims. Excessive Cmpensatin Allwed PI s t charge a grant fr the prtin f summer salary that was in excess f the PI s annualized salary. Cst Sharing/Matching Amunts apprpriated fr cst sharing were nt representative f the amunts actually paid by UCnn. May Clinic ($6.5 Millin Settlement) Auditrs investigated research accunting and that the Gvernment was charged fr research unrelated t the NIH grants that May received. Over expenditures were made. Imprper Transfers csts frm verspent grants and internal May cst centers included n under spent grants. Accunting system unable t mnitr and manage charges Crnell University ($4.4 Millin Settlement fr Effrt; $2.6 millin fr False Claims Act Vilatin) Auditrs investigated a physician ver billing an NIH grant. said Weill Medical Cllege, part f Crnell, 'defrauded the gvernment and made false statements' when a principal investigatr n the grants in questin 'failed t disclse t the gvernment the full extent f her varius active research prjects' and that 'Weill Medical Cllege knew, r shuld have knwn, that its emplyee failed t fully disclse her active research prjects in the grant applicatins submitted t the gvernment such that her research cmmitments exceeded 100% f her available time'. Several research prjects Crnell had said it wuld carry ut existed nly n paper. The mney fr the children s center was being used t treat many adults, and the center enrlled peple as study subjects wh didn t have the diseases being studied.

4 Crnell was billing the NIH fr nurses wh were suppsed t fcus exclusively n pediatric research. Yet they were rutinely pulled ut t treat regular patients. Yale University PI did nt fully disclse, that all her active research prjects exceeded 100%, in grant applicatins submitted t NIH and DOD Crnell has admitted n wrngding, insisting it had brad discretin n hw it spent the mney but agreed t pay a $4.4 millin settlement t the gvernment. Auditrs reviewed dcumentatin t supprt salary cst transfers & reviewed s stating transfers were necessary t spend dwn funds. PI failed t prvide the 25% level f effrt prpsed in subaward applicatin, PI did nt submit effrt reprts fr lab technician, tw effrt reprts nt cnfirmed. University des nt have prcedures fr mnitring the budgeted r minimum level f effrt fr key persnnel. $151,000 transferred frm ther grants r frm general funds. In sme cases, it was because the grant award was apprved late (a cmmn ccurrence), but the dcumentatin was missing that was required by the University's wn prcedure manual t verify that the transferred charges were apprpriate t the grant. But in ther cases, funds were transferred t spend dwn the subgrant award, which is nt allwed. A ftnte tells us that initially an prvided t the auditrs had been altered t mit the explanatin f why the transfer had ccurred. Dartmuth Auditrs reviewed 100% PI effrt and prpsal activity. Overstated Salaries (Labr Distributin). 18 mnths effrt charged (100% f 4 PI s salaries) t NIH grants, but PI s taught a curse. PI s verbally estimated t auditrs that they spent 20% f their time n prpsal activity. The Cllege charged salaries that were nt cnsistent with the PI s actual activity and used an verstated labr distributin percentage.

5 UC Berkeley Need t establish prcedures t accunt fr grant applicatin activity. Adpt HHS certificatin language. Recncile center recrds with accunting system. Auditrs reviewed dcumentatin f CS effrt n 10 cperative agreements. UC Berkeley recrded cst share in their accunting system. One center used its wn recrds t reprt cst share which did nt agree with the University s accunting system. Center culd nt prvide dcumentatin t supprt their recrds. Cst shared effrt nt reprted accurately Unable t supprt salary csts claimed by center staff actual percentage f time spent n prject was nt dcumented. Gergia State University Cperative Agreements were reviewed. Payrll Expenses Center charged fr wrk dne n anther grant, GSU did nt take adequate care in maintaining required dcumentatin, and did nt always fllw its plicies and prcedures. Transfers made withut explanatin r surce dcumentatin. Culd nt lcate persnal actin frms. University f Pennsylvania Weaknesses in the effrt reprting system. The audit disclsed tw majr systemic internal cntrl 1) UPENN s business managers were certifying labr effrt reprts, thugh they were nt in a psitin t knw whether wrk was perfrmed, and 2) effrt reprts were nt certified in a timely manner as specified by UPENN plicy. N guidance regarding suitable means f verificatin. (Auditrs lked fr specific prcedures explaining the types f dcumentatin that was acceptable as supprt fr infrmatin reflected n the effrt reprts'.)

6 Specific prcedures t help business managers understand the types f dcuments that were necessary t supprt the effrt reprts. Department Chairs were nt held accuntable fr ensuring effrt reprts were cmpleted within the 45 day turnarund perid. The auditrs disagree with UPENN s assessment that its annual A 133 audits and internal audits met the requirement f an independent evaluatin f the payrll distributin system. Lked at specific spnsred prgrams nt entire system. Cal Tech Auditrs reviews transfers f graduate student salary frm a federal award Findings Cst Transferred t Grant Frm An Overspent Federal Award. Establish a frmal requirement fr an independent evaluatin f the PDC system t ensure its effectiveness and full cmpliance with OMB,, and Caltech standards. Establish a methdlgy fr reasnably estimating and calculating an amunt f cmmitted cst shared PI effrt t be reprted in the PDC system fr spnsred prjects with n PI salary reimbursements. Cst Share Audits & Summaries Hward University March 2006 Funding Surce: Natinal Science Fundatin Descriptin: OIG was unable t verify $12.3 millin in claimed cst sharing; n supprting dcumentatin fr faculty salary charges f $187,000; failure t mnitr sub recipients and failure t flw dwn required clauses int subagreements; duplicate stipend payments made t nn Hward trainees and n dcumentatin t supprt ver $109,000 in stipend payments and travel allwances Cmpliance Issues Cst sharing Accunting system Effrt reprting

7 Mnitring sub recipients Settlement/Enfrcement Actins Develp written plicies and prcedures manual fr administering grants Establish a Research Cmpliance Officer and a Cmpliance Officer t versee all spnsred research Update and revise financial management and accunting system sftware (cst sharing, effrt reprting) Mdify subagreement terms and cnditins Recver duplicate payments Establish PI certificatin prgram and training prgram fr faculty members Require independent auditrs t assess implementatin f crrective actins Texas State Technical Cllege June 2003 Funding Surce: Natinal Science Fundatin Descriptin: Auditrs tested fr cmpliance with cst sharing bligatins under a $1.5M technlgy training grant. The Cllege had prpsed t incur $5.7M f cst sharing, but failed t meet its bligatin. The Cllege als failed t certify effrt reprts n a timely basis, and did nt adequately mnitr subawardees. Cmpliance Issues Cst sharing Effrt reprting Subrecipient mnitring Settlement/Enfrcement Actins The Cllege cncurred with the auditr's findings and instituted a crrective actin plan

8 University f Suth Dakta March 2005 Funding Surce: Natinal Science Fundatin Descriptin: OIG reviewed csts claimed n three awards (ttaling $2M) fr cmpliance with award terms and cnditins, and fr allcability and allwability f cst sharing and ther csts. Audit questined $142,593 and cncluded that USD did nt have a frmalized system f determining which csts were direct and indirect. Audit als fund the fllwing: incrrect claims f cst sharing; subawards and subcntracts that were nt adequately managed; imprper augmentatin f faculty salaries after receipt f the award; and payments t cnsultants fr prpsal preparatin charged t the award. Cmpliance Issues Direct csts vs. Indirect csts Institutinal base salary Cst sharing Subrecipient mnitring Settlement/Enfrcement Actins USD reimbursed fr prpsal preparatin csts USD cnceded that faculty salaries were imprperly augmented USD revised its subcntract dcuments and increased spnsred research staffing Audit findings f fraud & false claims against University persnnel 05/01/07 Barbara Nye, Tennessee State University federal felny charge f making false statements t 03/31/06 NIH & FDA Civil Cmplaint against PI, Steven Raper, M.D.

9 01/20/06 Gergetwn University Medical Center departmental Administratr Adriana Santamaria & Sister Incarceratin and Restitutin 10/04/2005 GWU $1,825,000 False Claims Settlement 3 year Prisn Sentence fr PI 10/24/05 Gerge Washingtn University Adjunct Prfessr 5 Mnth Prisn Sentence 10/22/06 University f Vermnt Pehlman (ne f the mst expansive cases f scientific fraud & first PI t serve jail time fr fabricating data) 12/16/97 Medical Cllege f Gergia $10,000,000 stlen, 5 year prisn sentence fr PI