Audit of Health Resources and Services Administration Cooperative Agreement Number U69-HA-00040 University of Southern California Los Angeles, California

The objectives of this audit were to evaluate the effectiveness of the project management and the allowability of the costs. Our review disclosed that the University of Southern California (USC) did not meet the project objectives, conducted research on human subjects without proper authorization, did not adequately resolve a conflict of interest, and claimed costs that were not allowable for Federal reimbursement. This occurred because: (i) inexperienced personnel were assigned to implement critical aspects of the program, (ii) the co-principal investigator did not agree with the Institutional Review Board's conclusion that the program was conducting research involving human subjects, (iii) USC had not followed through to rectify the conflict of interest situation, and (iv) oversight of the award expenditures was not adequate. We made recommendations to improve USC's grant administration and oversight, and to refund over $1.0 million in unallowable costs.