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Emerging Issues and Hot Topics In Higher Education Compliance June 5, 2007. Office of Inspector General Office of Counsel to the Inspector General. Office of Inspector General.
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Emerging Issues and Hot Topics In Higher Education Compliance June 5, 2007 Office of Inspector GeneralOffice of Counsel to the Inspector General
Office of Inspector General • Under the Inspector General Act of 1978, OIG is responsible for preventing and detecting fraud and abuse in programs of the Department of Health and Human Services.
Office of Inspector General • OIG conducts audits, investigations, and evaluations, and promotes compliance measures. • OIG does NOT set the rules or take administrative action against institutions
OIG workplan items • Level of Commitment and Effort Reporting • Cost Transfers • University Administrative and Clerical Salaries
OIG workplan items • NIH Monitoring of Extramural Conflicts of Interest • PHS regulations at 42 CFR Part 50 require institutions to maintain a written, enforced policy on COI. • Must report to HHS when PI fails to comply with institution policy and the COI has biased the research
OIG workplan items • NIH handling of employee conflicts of interest • NIH monitoring of research grants
OIG workplan • Use of Data and Safety Monitoring Boards in Clinical Trials • Public Health Laboratory Preparedness
SAS No. 112, Communicating Internal Control Matters Identified in an Audit
SAS No. 112 • SAS 112 supersedes SAS 60, Communication of Internal Control Related Matters Noted in an Audit • The term reportable condition is no longer used.
SAS No. 112 • Written from perspective of internal control over financial auditing • OMB developing an interim final rule to amend Circular A-133
SAS No. 112 • Provides definitions of control deficiency, significant deficiency, and material weakness • Each of these terms must be applied in the A-133 context
Circular A-133 audits • All significant deficiencies and material weaknesses to be included in Yellow Book (A-133) report • Control deficiencies that are not significant deficiencies would go in management letter unless clearly inconsequential
SAS No. 112 • Also states that nothing precludes the auditor from communicating tomanagement and those charged withgovernance other matters that the auditor: • Believes to be of potential benefit to the entity • Has been requested to communicate
Questions? • Richard Stern • Senior Counsel • Office of Inspector General • U.S. Department of Health and Human Services • Richard.Stern@oig.hhs.gov • 202-205-0572 Office of Counsel to the Inspector General