Office of Inspector General Office of Counsel to the by afr15630


									Office of Inspector General
Office of Counsel to the Inspector

 Emerging Issues and Hot Topics
 In Higher Education Compliance
            June 5, 2007
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
OIG workplan
 OIG workplan items

• Level of Commitment and Effort

• 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
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
SAS No. 112
   Also states that nothing precludes
    the auditor from communicating to
    management and those charged with
    governance other matters that the
    – Believes to be of potential benefit to the
    – Has been requested to communicate

• Richard Stern
• Senior Counsel
• Office of Inspector General
• U.S. Department of Health and Human
• 202-205-0572

                             Office of Counsel to the Inspector General

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