{"id":37,"date":"2016-04-16T16:23:21","date_gmt":"2016-04-16T16:23:21","guid":{"rendered":"http:\/\/blogs.luc.edu\/compliance\/?p=37"},"modified":"2016-04-16T16:23:21","modified_gmt":"2016-04-16T16:23:21","slug":"adding-federal-grant-compliance-to-the-audit-plan-the-university-of-florida-case","status":"publish","type":"post","link":"https:\/\/blogs.luc.edu\/compliance\/?p=37","title":{"rendered":"Adding Federal Grant Compliance to the Audit Plan: the University of Florida Case"},"content":{"rendered":"

Greg Grabinski<\/em>
\nExecutive Editor<\/em>
\nLoyola University Chicago School of Law, JD 2016<\/em><\/p>\n

 <\/p>\n

One of the best sources for designing a compliance program\u2019s annual audit plan is to look around to see what is happening at peer institutions.\u00a0 If there is a regulatory settlement in a peer organization\u2019s similar business line, then the subject-matter should be added to the compliance audit plan list. \u00a0The University of Florida (UF) provides good example of lessons learned for federal grant compliance.<\/p>\n

On November 20, 2015, the Department of Justice announced that UF\u00a0agreed to pay $19.875 million to settle False Claims Act allegations that it improperly billed the U.S. Department of Health and Human Services for administrative costs and salaries associated with hundreds of federal grants. The grants at issue were administered from UF\u2019s campuses at Gainesville and Jacksonville between 2005 and December 2010.<\/p>\n

The federal government alleged that the university \u2013 which receives millions of dollars in grant funding every year \u2013 over-billed hundreds of grants for the costs of its employees\u2019 salaries, where there was a lack of documentation to substantiate those costs. In addition, the government claimed that the university directly charged some grants for costs related to certain equipment and supplies which were supposedly prohibited pursuant to federal regulations associated with the grants. Finally, the United States alleged that the university inflated the costs for services performed by Jacksonville Healthcare Inc., an entity affiliated with UF\u2019s Jacksonville campus.<\/p>\n

UF officials stated that they first discovered the improper use of funds during an internal audit in 2005 and that those issues \u201chave since been remedied with significant upgrades in systems and procedures.\u201d In particular, UF has installed a new software platform, which has enhanced its ability to manage the verification processes associated with its federally funded projects. In addition, researchers are now required to undergo training on federal accounting requirements. Continuous training, auditing and software updates will need to be maintained throughout UF\u2019s systems as well as in any health care system looking to avoid such violations.<\/p>\n

The UF case highlights a high risk area for any organization receiving federal grants, namely the accuracy of the charges booked against the grants.\u00a0 Not only are there a host of federal regulations on how the finances of grants are managed and complex\u00a0parameters governing\u00a0what costs can be charged to the grant, many grants contain their own restrictions on allowance\u00a0of certain charges unique to each grant. The lesson learned is clear: compliance programs for organizations that take federal grants should have grant compliance on their annual compliance audit plans.<\/p>\n

 <\/p>\n

Resources<\/p>\n

http:\/\/www.justice.gov\/opa\/pr\/university-florida-agrees-pay-19875-million-settle-false-claims-act-allegations<\/a><\/p>\n

http:\/\/news.wjct.org\/post\/university-florida-agrees-198m-federal-settlement<\/a><\/p>\n

 <\/p>\n","protected":false},"excerpt":{"rendered":"

Greg Grabinski Executive Editor Loyola University Chicago School of Law, JD 2016   One of the best sources for designing a compliance program\u2019s annual audit plan is to look around to see what is happening at peer institutions.\u00a0 If there is a regulatory settlement in a peer organization\u2019s similar business line, then the subject-matter should …
Read more<\/a><\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[51],"tags":[119,468,806,820,826,2056],"class_list":["post-37","post","type-post","status-publish","format-standard","hentry","category-compliance-the-law","tag-accounting","tag-compliance","tag-fca","tag-federal-accounting","tag-federal-grants","tag-university-of-florida"],"_links":{"self":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts\/37","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=37"}],"version-history":[{"count":0,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts\/37\/revisions"}],"wp:attachment":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=37"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=37"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=37"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}