Office of Inspector General Office of Counsel to the Inspector General

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Office of Inspector GeneralOffice of Counsel to
the Inspector General

• Emerging Issues and Hot Topics
• In Higher Education Compliance
• June 5, 2007

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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.

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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      

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OIG workplan
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OIG workplan items

• Level of Commitment and Effort Reporting
• Cost Transfers
• University Administrative and Clerical Salaries

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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

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OIG workplan items

• NIH handling of employee conflicts of interest
• NIH monitoring of research grants

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OIG workplan

• Use of Data and Safety Monitoring Boards in
  Clinical Trials
• Public Health Laboratory Preparedness

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SAS No. 112, Communicating Internal Control
Matters Identified in an Audit
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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.

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SAS No. 112

• Written from perspective of internal control over
  financial auditing
• OMB developing an interim final rule to amend
  Circular A-133

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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

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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

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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

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Questions?

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

Office of Counsel to the Inspector General