Audit 11002

Program information: Federal Program: Provider Relief Fund (PRF) Assistance Listing Number: 93.498 Federal Agency: Department of Health & Human Services Award Year: PRF Period 5: Funds received January 1, 2022 through June 30, 2022 Criteria or requirement: Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Reporting (L) – Special Reporting Under the terms and conditions of the award, Provider Relief Funds (PRF) are subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information based on the period reported on, which includes the “Other Provider Relief Fund (Including Phase 4) Expenses” (PRF expenses). The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states that PRF payments may not be applied to the same expenses and lost revenues that were reported on in prior reporting periods. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding: During our testing over reporting, we observed management did not have effective internal controls in place to ensure PRF expenses reported in the period 5 portal report were not duplicated from the period 4 report, resulting in an overstatement of cumulative PRF expenses reported through the Portal and an overstatement of remaining unreimbursed lost revenues remaining after period 5. Cause and possible asserted effect: Controls were not operating effectively to detect and correct duplicate PRF expenses shown on the portal reporting between period 4 and period 5. Identification of questioned costs and how they were computed: $1,484,296 in duplicate “Other Provider Relief Fund (Including Phase 4) Expenses” shown on the portal reporting on the period 5 portal report. Sample Statistically Valid: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding from prior year: This matter is a repeat of the control deficiency documented in finding 2022-001 in the immediately preceding year audit. Recommendation: We recommend PeaceHealth management enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that duplicate information is not reported. Views of Responsible Officials: Despite the duplicated PRF expenses, there remained sufficient lost revenues in excess of PRF payments cumulatively received for Period 1 through 5; therefore, the Corporation has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program for PRF expenses. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions, if required. As of the date of this report, PeaceHealth Networks has reported on all PRF funds received and has no future portal reporting obligations.

Program information: Federal Program: Provider Relief Fund (PRF) Assistance Listing Number: 93.498 Federal Agency: Department of Health & Human Services Award Year: PRF Period 5: Funds received January 1, 2022 through June 30, 2022 Criteria or requirement: Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Reporting (L) – Special Reporting Under the terms and conditions of the award, Provider Relief Funds (PRF) are subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information based on the period reported on, which includes the “Other Provider Relief Fund (Including Phase 4) Expenses” (PRF expenses). The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states that PRF payments may not be applied to the same expenses and lost revenues that were reported on in prior reporting periods. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding: During our testing over reporting, we observed management did not have effective internal controls in place to ensure PRF expenses reported in the period 5 portal report were not duplicated from the period 4 report, resulting in an overstatement of cumulative PRF expenses reported through the Portal and an overstatement of remaining unreimbursed lost revenues remaining after period 5. Cause and possible asserted effect: Controls were not operating effectively to detect and correct duplicate PRF expenses shown on the portal reporting between period 4 and period 5. Identification of questioned costs and how they were computed: $1,484,296 in duplicate “Other Provider Relief Fund (Including Phase 4) Expenses” shown on the portal reporting on the period 5 portal report. Sample Statistically Valid: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding from prior year: This matter is a repeat of the control deficiency documented in finding 2022-001 in the immediately preceding year audit. Recommendation: We recommend PeaceHealth management enhance their internal control process to ensure the data underlying the portal reporting is appropriately reviewed by an individual other than the preparer to ensure that duplicate information is not reported. Views of Responsible Officials: Despite the duplicated PRF expenses, there remained sufficient lost revenues in excess of PRF payments cumulatively received for Period 1 through 5; therefore, the Corporation has demonstrated it did earn all of the PRF payments received. This matter was isolated to the error in reporting requirements under the Federal grant program for PRF expenses. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions, if required. As of the date of this report, PeaceHealth Networks has reported on all PRF funds received and has no future portal reporting obligations.