Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs / Cost Principles, E. Eligibility, and N. Special Tests and Provisions ? Material Weakness in Internal Controls Over Compliance Identification of the federal program: Assistance Listing 93.461 ? COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured (U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) (HRSA COVID-19 Uninsured Program) 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: 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 statues, 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 (also known as the Green Book) issued by the Comptroller General of the United States or the Internal Control ? Integrated Framework (COSO Framework) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 70 Section III ? Federal Award Findings and Questioned Costs (continued) Health and Human Services (HHS) ? (HRSA issued Terms and Conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (T&Cs) outlining requirements that recipients of funding from the HRSA COVID-19 Uninsured Program must comply with including the following sections: Testing Services, Treatment Services and Vaccine Administration, and General Provisions in FY2020 Consolidated Appropriations. Condition: The System did not appropriately design or implement internal controls over the HRSA COVID-19 Uninsured Program T&Cs as of and for the year ended December 31, 2022. Cause: Though there are internal controls in place with respect to the System?s revenue cycle, the System did not specifically have internal controls in place to ensure compliance with the HRSA COVID-19 Uninsured Program T&Cs. Effect or potential effect: If adequate internal controls are not designed and implemented, the System may not be in compliance with the HRSA COVID-19 Uninsured Program T&Cs, or the System may not take necessary actions required to comply with the HRSA COVID-19 Uninsured Program related to Uniform Guidance compliance requirements A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility, and N. Special Tests and Provisions Questioned costs: None. Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 71 Section III ? Federal Award Findings and Questioned Costs (continued) Context: The HRSA COVID-19 Uninsured Program had federal expenditures of $1,105,658 for the year ended December 31, 2022 and was determined to be Type A major federal program. Identification as a repeat finding, if applicable: This is a repeat finding. The prior year finding reference is Finding 2021-001. Recommendation: Due to the nature of this program and the timing of the finding identified in the prior year, the System did not have the opportunity to remediate the prior year finding. While this program likely will not exist in future periods, the System should implement internal controls to document its review and compliance with future federal program T&Cs and the Uniform Guidance and ensure appropriate documentation is retained to support the operating effectiveness of the implemented internal controls. Views of responsible officials: Management agrees with the finding and has developed a plan to address the finding and will ensure appropriate internal controls and documentation are in place for future programs.
Finding 2022-002 ? A. Activities Allowed or Unallowed and B. Allowable Costs / Cost Principles ? Material Weakness in Internal Controls Over Compliance Identification of the federal program: Assistance Listing 93.498 ? COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution (PRF Program) 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: 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 statues, 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 (also known as the Green Book) issued by the Comptroller General of the United States or the Internal Control ? Integrated Framework (COSO Framework) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 73 Section III ? Federal Award Findings and Questioned Costs (continued) Condition: The System did not appropriately design, implement, or retain documentation for internal controls over the PRF Program for the year ended December 31, 2022 to ensure compliance with requirements of the Uniform Guidance. Management also did not retain its documentation over the review and approval of the PRF Program terms and conditions (T&Cs). Cause: Though there are internal controls in place with respect to purchasing and revenue within the System, the System did not specifically have internal controls in place or operating effectively to ensure, or retain documentation to demonstrate compliance, with the PRF Program T&Cs and the Uniform Guidance. Effect or potential effect: If adequate internal controls are not designed, implemented, and documented the System may not be in compliance with the PRF Program T&Cs, or the System may not take necessary actions required to comply with the PRF Program related to all applicable Uniform Guidance compliance requirements. Questioned costs: None. Context: Total federal expenditures for Assistance Listing 93.498 totaled $27,741,256 for the year ended December 31, 2022. Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 74 Section III ? Federal Award Findings and Questioned Costs (continued) Identification as a repeat finding, if applicable: This is a repeat finding. The prior year finding reference is Finding 2021-003. Recommendation: Due to the nature of this program and the timing of the finding identified in the prior year, the System did not have the opportunity to remediate the prior year finding. While this program likely will not exist in future periods, the System should implement internal controls to document its review and compliance with future federal program T&Cs and the Uniform Guidance and ensure appropriate documentation is retained to support the operating effectiveness of the implemented internal controls. Views of responsible officials: Management agrees with the finding and has developed a plan to address the finding and will ensure appropriate internal controls and documentation are in place for future programs.
Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs / Cost Principles, E. Eligibility, and N. Special Tests and Provisions ? Material Weakness in Internal Controls Over Compliance Identification of the federal program: Assistance Listing 93.461 ? COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured (U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) (HRSA COVID-19 Uninsured Program) 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: 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 statues, 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 (also known as the Green Book) issued by the Comptroller General of the United States or the Internal Control ? Integrated Framework (COSO Framework) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 70 Section III ? Federal Award Findings and Questioned Costs (continued) Health and Human Services (HHS) ? (HRSA issued Terms and Conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (T&Cs) outlining requirements that recipients of funding from the HRSA COVID-19 Uninsured Program must comply with including the following sections: Testing Services, Treatment Services and Vaccine Administration, and General Provisions in FY2020 Consolidated Appropriations. Condition: The System did not appropriately design or implement internal controls over the HRSA COVID-19 Uninsured Program T&Cs as of and for the year ended December 31, 2022. Cause: Though there are internal controls in place with respect to the System?s revenue cycle, the System did not specifically have internal controls in place to ensure compliance with the HRSA COVID-19 Uninsured Program T&Cs. Effect or potential effect: If adequate internal controls are not designed and implemented, the System may not be in compliance with the HRSA COVID-19 Uninsured Program T&Cs, or the System may not take necessary actions required to comply with the HRSA COVID-19 Uninsured Program related to Uniform Guidance compliance requirements A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility, and N. Special Tests and Provisions Questioned costs: None. Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 71 Section III ? Federal Award Findings and Questioned Costs (continued) Context: The HRSA COVID-19 Uninsured Program had federal expenditures of $1,105,658 for the year ended December 31, 2022 and was determined to be Type A major federal program. Identification as a repeat finding, if applicable: This is a repeat finding. The prior year finding reference is Finding 2021-001. Recommendation: Due to the nature of this program and the timing of the finding identified in the prior year, the System did not have the opportunity to remediate the prior year finding. While this program likely will not exist in future periods, the System should implement internal controls to document its review and compliance with future federal program T&Cs and the Uniform Guidance and ensure appropriate documentation is retained to support the operating effectiveness of the implemented internal controls. Views of responsible officials: Management agrees with the finding and has developed a plan to address the finding and will ensure appropriate internal controls and documentation are in place for future programs.
Finding 2022-002 ? A. Activities Allowed or Unallowed and B. Allowable Costs / Cost Principles ? Material Weakness in Internal Controls Over Compliance Identification of the federal program: Assistance Listing 93.498 ? COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution (PRF Program) 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: 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 statues, 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 (also known as the Green Book) issued by the Comptroller General of the United States or the Internal Control ? Integrated Framework (COSO Framework) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 73 Section III ? Federal Award Findings and Questioned Costs (continued) Condition: The System did not appropriately design, implement, or retain documentation for internal controls over the PRF Program for the year ended December 31, 2022 to ensure compliance with requirements of the Uniform Guidance. Management also did not retain its documentation over the review and approval of the PRF Program terms and conditions (T&Cs). Cause: Though there are internal controls in place with respect to purchasing and revenue within the System, the System did not specifically have internal controls in place or operating effectively to ensure, or retain documentation to demonstrate compliance, with the PRF Program T&Cs and the Uniform Guidance. Effect or potential effect: If adequate internal controls are not designed, implemented, and documented the System may not be in compliance with the PRF Program T&Cs, or the System may not take necessary actions required to comply with the PRF Program related to all applicable Uniform Guidance compliance requirements. Questioned costs: None. Context: Total federal expenditures for Assistance Listing 93.498 totaled $27,741,256 for the year ended December 31, 2022. Kettering Health Schedule of Findings and Questioned Costs (continued) 2307-4310198 74 Section III ? Federal Award Findings and Questioned Costs (continued) Identification as a repeat finding, if applicable: This is a repeat finding. The prior year finding reference is Finding 2021-003. Recommendation: Due to the nature of this program and the timing of the finding identified in the prior year, the System did not have the opportunity to remediate the prior year finding. While this program likely will not exist in future periods, the System should implement internal controls to document its review and compliance with future federal program T&Cs and the Uniform Guidance and ensure appropriate documentation is retained to support the operating effectiveness of the implemented internal controls. Views of responsible officials: Management agrees with the finding and has developed a plan to address the finding and will ensure appropriate internal controls and documentation are in place for future programs.