Finding 2022-001 ? N4. Enrollment Reporting Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: There was no evidence that an authorized individual was reviewing the monthly SFRNSLC enrollment report for completeness and accuracy prior to its upload to the National Student Clearinghouse (NSC)/National Student Loan Data System for the period January 1, 2022 through September 30, 2022. Cause: Although a review of the enrollment report was performed by the Registrar, there was no formal documentation retained for the period January 1, 2022 through September 30, 2022, to evidence the procedures performed, what information was evaluated, the precision of the review, what types of noncompliance were identified, and what actions were taken to address any issues identified. Effect or potential effect: An incorrect enrollment report may be submitted. Questioned costs: None. Context: Management implemented internal controls on October 1, 2022, to include a monthly review of at least 12 students for accuracy and completeness. This control was tested for the period October 1, 2022 through December 31, 2022, and determined to be operating effectively. Total Federal Pell Grants and Federal Direct Loans for GSON were $845,056 and $6,869,688, respectively, representing 10.8% and 87.7%, respectively, of total Student Financial Assistance Cluster federal expenditures of $7,830,734. Identification as a repeat finding, if applicable: This is a partial repeat finding and is related to finding 2021-001 from the prior year. Recommendation: Management should continue to follow its internal control implemented on October 1, 2022, which documents the review process performed by the Registrar, including the students sampled and the specific data validated, the results of the review, and the follow-up actions taken, if any, and sign-off by the Registrar to evidence performance of the monthly review. Views of Responsible Officials: Management agrees with the finding and will continue to follow the internal control implemented in October 2022.
Finding 2022-002 ? Information Technology General Controls Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: BJC HealthCare did not implement all logical access controls that are required to be in place to support effective information technology general controls (ITGCs) for the Banner application. The controls that were not specifically implemented during the current period relate to user access review, user provisioning and user termination processes. As a result, Banner ITGCs, and therefore, Banner application controls, cannot be relied upon in the period of audit. Cause: Management did not appropriately implement a user access review for the period under audit. Effect or potential effect: There is a risk the data relevant to the Student Financial Assistance Cluster program stored within the student financial aid system may be inappropriately created or modified. Effective testing of the required logical access controls is to support effective ITGCs over the Banner application. As a result, the Banner application cannot be relied on for the audit period. Questioned costs: None. Context: Total expenditures for the Student Financial Assistance Cluster were $7,830,734 for the year ended December 31, 2022. Identification as a repeat finding, if applicable: This is a not a repeat finding from the prior year. Recommendation: Management should complete a user access review, including user provisioning and user termination processes, and retain documentation of the operation of controls. Views of responsible officials: Management agrees with the finding. GSON formalized a policy and procedure document regarding access controls to support effective ITGCs for the Banner application. A formal user access review will be completed semi-annually and results of the review, including actions taken, will be formally documented.
Finding 2022-001 ? N4. Enrollment Reporting Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: There was no evidence that an authorized individual was reviewing the monthly SFRNSLC enrollment report for completeness and accuracy prior to its upload to the National Student Clearinghouse (NSC)/National Student Loan Data System for the period January 1, 2022 through September 30, 2022. Cause: Although a review of the enrollment report was performed by the Registrar, there was no formal documentation retained for the period January 1, 2022 through September 30, 2022, to evidence the procedures performed, what information was evaluated, the precision of the review, what types of noncompliance were identified, and what actions were taken to address any issues identified. Effect or potential effect: An incorrect enrollment report may be submitted. Questioned costs: None. Context: Management implemented internal controls on October 1, 2022, to include a monthly review of at least 12 students for accuracy and completeness. This control was tested for the period October 1, 2022 through December 31, 2022, and determined to be operating effectively. Total Federal Pell Grants and Federal Direct Loans for GSON were $845,056 and $6,869,688, respectively, representing 10.8% and 87.7%, respectively, of total Student Financial Assistance Cluster federal expenditures of $7,830,734. Identification as a repeat finding, if applicable: This is a partial repeat finding and is related to finding 2021-001 from the prior year. Recommendation: Management should continue to follow its internal control implemented on October 1, 2022, which documents the review process performed by the Registrar, including the students sampled and the specific data validated, the results of the review, and the follow-up actions taken, if any, and sign-off by the Registrar to evidence performance of the monthly review. Views of Responsible Officials: Management agrees with the finding and will continue to follow the internal control implemented in October 2022.
Finding 2022-002 ? Information Technology General Controls Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: BJC HealthCare did not implement all logical access controls that are required to be in place to support effective information technology general controls (ITGCs) for the Banner application. The controls that were not specifically implemented during the current period relate to user access review, user provisioning and user termination processes. As a result, Banner ITGCs, and therefore, Banner application controls, cannot be relied upon in the period of audit. Cause: Management did not appropriately implement a user access review for the period under audit. Effect or potential effect: There is a risk the data relevant to the Student Financial Assistance Cluster program stored within the student financial aid system may be inappropriately created or modified. Effective testing of the required logical access controls is to support effective ITGCs over the Banner application. As a result, the Banner application cannot be relied on for the audit period. Questioned costs: None. Context: Total expenditures for the Student Financial Assistance Cluster were $7,830,734 for the year ended December 31, 2022. Identification as a repeat finding, if applicable: This is a not a repeat finding from the prior year. Recommendation: Management should complete a user access review, including user provisioning and user termination processes, and retain documentation of the operation of controls. Views of responsible officials: Management agrees with the finding. GSON formalized a policy and procedure document regarding access controls to support effective ITGCs for the Banner application. A formal user access review will be completed semi-annually and results of the review, including actions taken, will be formally documented.
Finding 2022-005 ? A. Activities Allowed or Unallowed and B. Allowable Costs/Cost Principles Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (Assistance Listing No. 93.498) (PRF) BJC HealthCare Location: Various Tax Identification Numbers: Various Payment Received Period: 07/01/2021?06/30/2021 (Period 3) and 07/01/2021?12/31/2021 (Period 4) Deadline to Use Funds: December 31, 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Evidence was not consistently retained to show review and approval of employee incentive pay expenses. In addition, we were unable to validate the control activities performed by the reviewer/approver for employee incentive pay expenses that were based on unit vacancy rates. Cause: Time cards can be processed without manager approval. Evidence of control activities performed by the reviewer/approver for employee incentive pay expenses that were based on unit vacancy rates was not retained. Effect or potential effect: BJC HealthCare may incur unallowable expenses or not be in compliance with the terms and conditions of the federal program, including relevant cost principles. Questioned costs: None. Context: Payroll-related expenses are $3,627,526, representing 10.9% of total PRF expenditures reported on the schedule of expenditures of federal awards of $33,214,104 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should reassess the design of internal controls over the review and approval of time cards. Evidence of control activities performed should be retained. Views of responsible officials: Management agrees with the finding as reported. Expenses will not be utilized in future PRF reporting periods. If, at some future date, additional funds are received and expenses are utilized for the PRF funds, BJC HealthCare will implement appropriate internal controls around review and approval of allowable activities and allowable costs.
Finding 2022-003 ? L. Reporting Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain supporting documentation over its review and approval of quarterly progress reports required to be submitted to FEMA during the period January 1, 2022 through June 30, 2022. While management had a process to prepare and review reports submitted under the FEMA program, sufficient documentation was not retained to support the process. In addition, for certain quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, the review was completed after submission of the quarterly progress report to FEMA. Cause: Internal controls over the review and approval of quarterly progress reports submitted to FEMA were not implemented until the third quarter of fiscal year 2022. In addition, internal controls implemented in the third quarter of fiscal year 2022 were not operating effectively. Effect or potential effect: Reports submitted to FEMA could be inaccurate or incomplete. Questioned costs: None. Context: Of the 16 quarterly progress reports submitted to FEMA during the year ended December 31, 2022, we were unable to test controls over the eight quarterly progress reports submitted during the period January 1, 2022 through June 30, 2022. We tested four of eight quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, and noted that for all four, the review was completed the day after the quarterly progress reports were submitted to FEMA. Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should follow its internal control implemented on July 1, 2022, over the timely review and approval of reports for accuracy and completeness and ensure the review is performed prior to the reports being submitted. Views of responsible officials: Management agrees with the finding and will implement controls and documentation over the timely review and approval of quarterly progress reports submitted to FEMA.
Finding 2022-004 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, H. Period of Performance and N. Special Tests and Provisions Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management implemented an internal control over the review and approval of a sample of FEMA expenses during the fiscal year for compliance with allowability, period of performance, and special tests and provisions requirements. However, the internal control did not include the following: ? A reconciliation to ensure the population subject to the internal control reconciled to the expenses claimed or to be claimed under the FEMA program. ? A review to ensure that invoices allocated between multiple project worksheets did not exceed claim in total. In addition, documentation over when the internal control was performed and by whom was not consistently maintained. Cause: Management?s internal control over the review and approval FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements was not properly designed. Effect or potential effect: Unallowable expenses could be charged to the FEMA program. Questioned costs: None. Context: Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is a partial repeat of finding 2021-004 from the prior year. Recommendation: Management should reassess its internal controls over the review and approval of FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements. Views of responsible officials: Management agrees with the finding and will implement controls and documentation 1) to demonstrate when the control was performed and by whom, 2) to ensure that invoices allocated between multiple project worksheets do not exceed the claim in total, and 3) to include a reconciliation to ensure the population ties to the expenses claimed and expenses to be claimed.
Finding 2022-003 ? L. Reporting Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain supporting documentation over its review and approval of quarterly progress reports required to be submitted to FEMA during the period January 1, 2022 through June 30, 2022. While management had a process to prepare and review reports submitted under the FEMA program, sufficient documentation was not retained to support the process. In addition, for certain quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, the review was completed after submission of the quarterly progress report to FEMA. Cause: Internal controls over the review and approval of quarterly progress reports submitted to FEMA were not implemented until the third quarter of fiscal year 2022. In addition, internal controls implemented in the third quarter of fiscal year 2022 were not operating effectively. Effect or potential effect: Reports submitted to FEMA could be inaccurate or incomplete. Questioned costs: None. Context: Of the 16 quarterly progress reports submitted to FEMA during the year ended December 31, 2022, we were unable to test controls over the eight quarterly progress reports submitted during the period January 1, 2022 through June 30, 2022. We tested four of eight quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, and noted that for all four, the review was completed the day after the quarterly progress reports were submitted to FEMA. Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should follow its internal control implemented on July 1, 2022, over the timely review and approval of reports for accuracy and completeness and ensure the review is performed prior to the reports being submitted. Views of responsible officials: Management agrees with the finding and will implement controls and documentation over the timely review and approval of quarterly progress reports submitted to FEMA.
Finding 2022-004 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, H. Period of Performance and N. Special Tests and Provisions Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management implemented an internal control over the review and approval of a sample of FEMA expenses during the fiscal year for compliance with allowability, period of performance, and special tests and provisions requirements. However, the internal control did not include the following: ? A reconciliation to ensure the population subject to the internal control reconciled to the expenses claimed or to be claimed under the FEMA program. ? A review to ensure that invoices allocated between multiple project worksheets did not exceed claim in total. In addition, documentation over when the internal control was performed and by whom was not consistently maintained. Cause: Management?s internal control over the review and approval FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements was not properly designed. Effect or potential effect: Unallowable expenses could be charged to the FEMA program. Questioned costs: None. Context: Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is a partial repeat of finding 2021-004 from the prior year. Recommendation: Management should reassess its internal controls over the review and approval of FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements. Views of responsible officials: Management agrees with the finding and will implement controls and documentation 1) to demonstrate when the control was performed and by whom, 2) to ensure that invoices allocated between multiple project worksheets do not exceed the claim in total, and 3) to include a reconciliation to ensure the population ties to the expenses claimed and expenses to be claimed.
Finding 2022-001 ? N4. Enrollment Reporting Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: There was no evidence that an authorized individual was reviewing the monthly SFRNSLC enrollment report for completeness and accuracy prior to its upload to the National Student Clearinghouse (NSC)/National Student Loan Data System for the period January 1, 2022 through September 30, 2022. Cause: Although a review of the enrollment report was performed by the Registrar, there was no formal documentation retained for the period January 1, 2022 through September 30, 2022, to evidence the procedures performed, what information was evaluated, the precision of the review, what types of noncompliance were identified, and what actions were taken to address any issues identified. Effect or potential effect: An incorrect enrollment report may be submitted. Questioned costs: None. Context: Management implemented internal controls on October 1, 2022, to include a monthly review of at least 12 students for accuracy and completeness. This control was tested for the period October 1, 2022 through December 31, 2022, and determined to be operating effectively. Total Federal Pell Grants and Federal Direct Loans for GSON were $845,056 and $6,869,688, respectively, representing 10.8% and 87.7%, respectively, of total Student Financial Assistance Cluster federal expenditures of $7,830,734. Identification as a repeat finding, if applicable: This is a partial repeat finding and is related to finding 2021-001 from the prior year. Recommendation: Management should continue to follow its internal control implemented on October 1, 2022, which documents the review process performed by the Registrar, including the students sampled and the specific data validated, the results of the review, and the follow-up actions taken, if any, and sign-off by the Registrar to evidence performance of the monthly review. Views of Responsible Officials: Management agrees with the finding and will continue to follow the internal control implemented in October 2022.
Finding 2022-002 ? Information Technology General Controls Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: BJC HealthCare did not implement all logical access controls that are required to be in place to support effective information technology general controls (ITGCs) for the Banner application. The controls that were not specifically implemented during the current period relate to user access review, user provisioning and user termination processes. As a result, Banner ITGCs, and therefore, Banner application controls, cannot be relied upon in the period of audit. Cause: Management did not appropriately implement a user access review for the period under audit. Effect or potential effect: There is a risk the data relevant to the Student Financial Assistance Cluster program stored within the student financial aid system may be inappropriately created or modified. Effective testing of the required logical access controls is to support effective ITGCs over the Banner application. As a result, the Banner application cannot be relied on for the audit period. Questioned costs: None. Context: Total expenditures for the Student Financial Assistance Cluster were $7,830,734 for the year ended December 31, 2022. Identification as a repeat finding, if applicable: This is a not a repeat finding from the prior year. Recommendation: Management should complete a user access review, including user provisioning and user termination processes, and retain documentation of the operation of controls. Views of responsible officials: Management agrees with the finding. GSON formalized a policy and procedure document regarding access controls to support effective ITGCs for the Banner application. A formal user access review will be completed semi-annually and results of the review, including actions taken, will be formally documented.
Finding 2022-001 ? N4. Enrollment Reporting Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: There was no evidence that an authorized individual was reviewing the monthly SFRNSLC enrollment report for completeness and accuracy prior to its upload to the National Student Clearinghouse (NSC)/National Student Loan Data System for the period January 1, 2022 through September 30, 2022. Cause: Although a review of the enrollment report was performed by the Registrar, there was no formal documentation retained for the period January 1, 2022 through September 30, 2022, to evidence the procedures performed, what information was evaluated, the precision of the review, what types of noncompliance were identified, and what actions were taken to address any issues identified. Effect or potential effect: An incorrect enrollment report may be submitted. Questioned costs: None. Context: Management implemented internal controls on October 1, 2022, to include a monthly review of at least 12 students for accuracy and completeness. This control was tested for the period October 1, 2022 through December 31, 2022, and determined to be operating effectively. Total Federal Pell Grants and Federal Direct Loans for GSON were $845,056 and $6,869,688, respectively, representing 10.8% and 87.7%, respectively, of total Student Financial Assistance Cluster federal expenditures of $7,830,734. Identification as a repeat finding, if applicable: This is a partial repeat finding and is related to finding 2021-001 from the prior year. Recommendation: Management should continue to follow its internal control implemented on October 1, 2022, which documents the review process performed by the Registrar, including the students sampled and the specific data validated, the results of the review, and the follow-up actions taken, if any, and sign-off by the Registrar to evidence performance of the monthly review. Views of Responsible Officials: Management agrees with the finding and will continue to follow the internal control implemented in October 2022.
Finding 2022-002 ? Information Technology General Controls Identification of the federal program: Federal Program: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing No. 84.063) and Federal Direct Student Loans (Assistance Listing No. 84.268) Federal Agency: United States Department of Education BJC HealthCare Location: Goldfarb School of Nursing Award Periods: January 1, 2022 through June 30, 2022 (included in award year July 1, 2021 through June 30, 2022), and July 1, 2022 through December 31, 2022 (included in award year July 1, 2022 through June 30, 2023) Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: BJC HealthCare did not implement all logical access controls that are required to be in place to support effective information technology general controls (ITGCs) for the Banner application. The controls that were not specifically implemented during the current period relate to user access review, user provisioning and user termination processes. As a result, Banner ITGCs, and therefore, Banner application controls, cannot be relied upon in the period of audit. Cause: Management did not appropriately implement a user access review for the period under audit. Effect or potential effect: There is a risk the data relevant to the Student Financial Assistance Cluster program stored within the student financial aid system may be inappropriately created or modified. Effective testing of the required logical access controls is to support effective ITGCs over the Banner application. As a result, the Banner application cannot be relied on for the audit period. Questioned costs: None. Context: Total expenditures for the Student Financial Assistance Cluster were $7,830,734 for the year ended December 31, 2022. Identification as a repeat finding, if applicable: This is a not a repeat finding from the prior year. Recommendation: Management should complete a user access review, including user provisioning and user termination processes, and retain documentation of the operation of controls. Views of responsible officials: Management agrees with the finding. GSON formalized a policy and procedure document regarding access controls to support effective ITGCs for the Banner application. A formal user access review will be completed semi-annually and results of the review, including actions taken, will be formally documented.
Finding 2022-005 ? A. Activities Allowed or Unallowed and B. Allowable Costs/Cost Principles Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (Assistance Listing No. 93.498) (PRF) BJC HealthCare Location: Various Tax Identification Numbers: Various Payment Received Period: 07/01/2021?06/30/2021 (Period 3) and 07/01/2021?12/31/2021 (Period 4) Deadline to Use Funds: December 31, 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Evidence was not consistently retained to show review and approval of employee incentive pay expenses. In addition, we were unable to validate the control activities performed by the reviewer/approver for employee incentive pay expenses that were based on unit vacancy rates. Cause: Time cards can be processed without manager approval. Evidence of control activities performed by the reviewer/approver for employee incentive pay expenses that were based on unit vacancy rates was not retained. Effect or potential effect: BJC HealthCare may incur unallowable expenses or not be in compliance with the terms and conditions of the federal program, including relevant cost principles. Questioned costs: None. Context: Payroll-related expenses are $3,627,526, representing 10.9% of total PRF expenditures reported on the schedule of expenditures of federal awards of $33,214,104 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should reassess the design of internal controls over the review and approval of time cards. Evidence of control activities performed should be retained. Views of responsible officials: Management agrees with the finding as reported. Expenses will not be utilized in future PRF reporting periods. If, at some future date, additional funds are received and expenses are utilized for the PRF funds, BJC HealthCare will implement appropriate internal controls around review and approval of allowable activities and allowable costs.
Finding 2022-003 ? L. Reporting Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain supporting documentation over its review and approval of quarterly progress reports required to be submitted to FEMA during the period January 1, 2022 through June 30, 2022. While management had a process to prepare and review reports submitted under the FEMA program, sufficient documentation was not retained to support the process. In addition, for certain quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, the review was completed after submission of the quarterly progress report to FEMA. Cause: Internal controls over the review and approval of quarterly progress reports submitted to FEMA were not implemented until the third quarter of fiscal year 2022. In addition, internal controls implemented in the third quarter of fiscal year 2022 were not operating effectively. Effect or potential effect: Reports submitted to FEMA could be inaccurate or incomplete. Questioned costs: None. Context: Of the 16 quarterly progress reports submitted to FEMA during the year ended December 31, 2022, we were unable to test controls over the eight quarterly progress reports submitted during the period January 1, 2022 through June 30, 2022. We tested four of eight quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, and noted that for all four, the review was completed the day after the quarterly progress reports were submitted to FEMA. Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should follow its internal control implemented on July 1, 2022, over the timely review and approval of reports for accuracy and completeness and ensure the review is performed prior to the reports being submitted. Views of responsible officials: Management agrees with the finding and will implement controls and documentation over the timely review and approval of quarterly progress reports submitted to FEMA.
Finding 2022-004 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, H. Period of Performance and N. Special Tests and Provisions Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management implemented an internal control over the review and approval of a sample of FEMA expenses during the fiscal year for compliance with allowability, period of performance, and special tests and provisions requirements. However, the internal control did not include the following: ? A reconciliation to ensure the population subject to the internal control reconciled to the expenses claimed or to be claimed under the FEMA program. ? A review to ensure that invoices allocated between multiple project worksheets did not exceed claim in total. In addition, documentation over when the internal control was performed and by whom was not consistently maintained. Cause: Management?s internal control over the review and approval FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements was not properly designed. Effect or potential effect: Unallowable expenses could be charged to the FEMA program. Questioned costs: None. Context: Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is a partial repeat of finding 2021-004 from the prior year. Recommendation: Management should reassess its internal controls over the review and approval of FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements. Views of responsible officials: Management agrees with the finding and will implement controls and documentation 1) to demonstrate when the control was performed and by whom, 2) to ensure that invoices allocated between multiple project worksheets do not exceed the claim in total, and 3) to include a reconciliation to ensure the population ties to the expenses claimed and expenses to be claimed.
Finding 2022-003 ? L. Reporting Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain supporting documentation over its review and approval of quarterly progress reports required to be submitted to FEMA during the period January 1, 2022 through June 30, 2022. While management had a process to prepare and review reports submitted under the FEMA program, sufficient documentation was not retained to support the process. In addition, for certain quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, the review was completed after submission of the quarterly progress report to FEMA. Cause: Internal controls over the review and approval of quarterly progress reports submitted to FEMA were not implemented until the third quarter of fiscal year 2022. In addition, internal controls implemented in the third quarter of fiscal year 2022 were not operating effectively. Effect or potential effect: Reports submitted to FEMA could be inaccurate or incomplete. Questioned costs: None. Context: Of the 16 quarterly progress reports submitted to FEMA during the year ended December 31, 2022, we were unable to test controls over the eight quarterly progress reports submitted during the period January 1, 2022 through June 30, 2022. We tested four of eight quarterly progress reports submitted to FEMA during the period July 1, 2022 through December 31, 2022, and noted that for all four, the review was completed the day after the quarterly progress reports were submitted to FEMA. Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should follow its internal control implemented on July 1, 2022, over the timely review and approval of reports for accuracy and completeness and ensure the review is performed prior to the reports being submitted. Views of responsible officials: Management agrees with the finding and will implement controls and documentation over the timely review and approval of quarterly progress reports submitted to FEMA.
Finding 2022-004 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, H. Period of Performance and N. Special Tests and Provisions Identification of the federal program: Federal Agency: U.S. Department of Homeland Security, Federal Emergency Management Agency (FEMA) Pass-Through Entities: Missouri State Emergency Management Agency and Illinois Emergency Management Agency Federal Program: COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing No. 97.036) BJC HealthCare Location: Various Pass-Through Award Numbers: Pass-Through Award Periods: PA-07-MO-4490-PW-00281(0) 08/01/2020?09/30/2021 PA-07-MO-4490-PW-00492(664) 01/01/2020?05/11/2023 PA-07-MO-4490-PW-00508(688) 01/21/2020?03/31/2021 PA-05-IL-4489-PW-00787(0), PA-05-IL-4489-PW-00787(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00788(0), PA-05-IL-4489-PW-00788(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-00789(0), PA-05-IL-4489-PW-00789(1) 07/01/2020?12/31/2021 PA-05-IL-4489-PW-01324(1704) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01329(1701) 01/01/2020?05/11/2023 PA-05-IL-4489-PW-01330(1702) 01/01/2020?05/11/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303(a) of the Uniform Guidance states the following regarding the auditee and internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management implemented an internal control over the review and approval of a sample of FEMA expenses during the fiscal year for compliance with allowability, period of performance, and special tests and provisions requirements. However, the internal control did not include the following: ? A reconciliation to ensure the population subject to the internal control reconciled to the expenses claimed or to be claimed under the FEMA program. ? A review to ensure that invoices allocated between multiple project worksheets did not exceed claim in total. In addition, documentation over when the internal control was performed and by whom was not consistently maintained. Cause: Management?s internal control over the review and approval FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements was not properly designed. Effect or potential effect: Unallowable expenses could be charged to the FEMA program. Questioned costs: None. Context: Total FEMA expenditures reported on the schedule of expenditures of federal awards are $42,087,643 for the year ended December 31, 2022. Identification as a repeat finding: This finding is a partial repeat of finding 2021-004 from the prior year. Recommendation: Management should reassess its internal controls over the review and approval of FEMA expenses for compliance with allowability, period of performance, and special tests and provisions requirements. Views of responsible officials: Management agrees with the finding and will implement controls and documentation 1) to demonstrate when the control was performed and by whom, 2) to ensure that invoices allocated between multiple project worksheets do not exceed the claim in total, and 3) to include a reconciliation to ensure the population ties to the expenses claimed and expenses to be claimed.