 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

OR
OREGON
ID
CA
CALIFORNIA
NV
AZ
ARIZONA
AK
HI
ND
SD
NE
VT
NH ME
MN
IA
MO
MISSOURI
AR
WI
IL
MS
MS.
MI
PA
IN
KENT
KY
TN
OH
WV
DC
VA
NC
SC
NY
MA
CT
RI
NJ
PUERTO RICO
DE
MD
AL GA
LA
FL
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

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

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

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

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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.

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
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
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
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
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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


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

Draft Report: OIG issues to auditee. 30day comment period.
OIG issues final report, with auditee comments summarized & OIG response included.
Appendix has auditee’s full comments.
OIG receives comments, incorporates into report, and addresses them in the report.
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 afterthe-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