FAC Explorer

Audit 18892

FY End
2022-06-30
Total Expended
$511.42M
Findings
16
Programs
73
Organization: Trinity Health (MI)
Year: 2022 Accepted: 2023-03-19
Auditor: Deloitte & Touche LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
15774 2022-007 - - A
15775 2022-008 - Yes E
15776 2022-005 - - L
15777 2022-006 - - E
15778 2022-001 - - L
15779 2022-002 - - C
15780 2022-003 - - C
15781 2022-004 - - L
592216 2022-007 - - A
592217 2022-008 - Yes E
592218 2022-005 - - L
592219 2022-006 - - E
592220 2022-001 - - L
592221 2022-002 - - C
592222 2022-003 - - C
592223 2022-004 - - L

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $437.80M Yes 1
93.395 Cancer Treatment Research $3.31M Yes 0
84.268 Federal Direct Student Loans $2.61M Yes 0
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $1.74M - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.34M - 0
93.261 National Diabetes Prevention Program: Preventing Type 2 Diabetes Among People at High Risk $1.32M Yes 2
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $490,305 - 0
93.650 Accountable Health Communities $482,098 - 0
93.461 Covid-19 Testing for the Uninsured $463,967 Yes 0
93.917 Hiv Care Formula Grants $435,824 - 0
93.575 Child Care and Development Block Grant $374,477 - 0
93.150 Projects for Assistance in Transition From Homelessness (path) $301,933 - 0
93.778 Medical Assistance Program $290,890 - 0
93.011 National Organizations of State and Local Officials $261,609 - 0
93.155 Rural Health Research Centers $252,916 Yes 0
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $242,581 - 0
93.914 Hiv Emergency Relief Project Grants $200,711 - 0
93.994 Maternal and Child Health Services Block Grant to the States $184,369 - 0
14.241 Housing Opportunities for Persons with Aids $180,053 - 0
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $171,404 - 0
84.063 Federal Pell Grant Program $156,515 Yes 0
93.667 Social Services Block Grant $152,319 - 0
14.231 Emergency Solutions Grant Program $150,000 - 0
93.604 Assistance for Torture Victims $136,091 - 0
93.276 Drug-Free Communities Support Program Grants $135,075 - 0
93.566 Refugee and Entrant Assistance_state Administered Programs $104,053 - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $97,279 - 0
97.067 Homeland Security Grant Program $90,328 - 0
16.831 Children of Incarcerated Parents $87,219 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $83,971 - 0
93.268 Immunization Cooperative Agreements $75,730 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $67,246 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $66,697 - 0
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $65,746 - 0
16.575 Crime Victim Assistance $62,550 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $53,800 - 0
93.697 Covid-19 Testing for Rural Health Clinics $53,746 - 0
16.838 Comprehensive Opioid Abuse Site-Based Program $53,386 - 0
93.839 Blood Diseases and Resources Research $53,000 Yes 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $52,010 - 0
84.007 Federal Supplemental Educational Opportunity Grants $51,921 Yes 0
16.588 Violence Against Women Formula Grants $49,607 - 0
93.940 Hiv Prevention Activities_health Department Based $41,903 - 0
14.218 Community Development Block Grants/entitlement Grants $41,302 - 0
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $40,665 - 0
93.889 National Bioterrorism Hospital Preparedness Program $40,000 - 0
93.958 Block Grants for Community Mental Health Services $34,798 - 0
93.364 Nursing Student Loans $24,541 Yes 1
10.558 Child and Adult Care Food Program $24,522 - 0
93.866 Aging Research $24,282 Yes 0
93.879 Medical Library Assistance $22,413 - 0
14.267 Continuum of Care Program $20,796 - 0
93.310 Trans-Nih Research Support $20,295 Yes 0
16.529 Education, Training, and Enhanced Services to End Violence Against and Abuse of Women with Disabilities $17,338 - 0
97.024 Emergency Food and Shelter National Board Program $12,500 - 0
93.247 Advanced Nursing Education Grant Program $12,348 - 0
93.301 Small Rural Hospital Improvement Grant Program $12,094 - 0
93.399 Cancer Control $11,675 Yes 0
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $10,352 Yes 0
93.226 Research on Healthcare Costs, Quality and Outcomes $8,910 Yes 0
16.017 Sexual Assault Services Formula Program $8,657 - 0
93.624 Aca - State Innovation Models: Funding for Model Design and Model Testing Assistance $7,614 - 0
93.242 Mental Health Research Grants $7,286 Yes 0
93.069 Public Health Emergency Preparedness $6,078 - 0
16.813 Nics Act Record Improvement Program $6,000 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $5,480 Yes 0
16.320 Services for Trafficking Victims $5,173 - 0
21.019 Coronavirus Relief Fund $5,000 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $4,049 - 0
84.425 Education Stabilization Fund $3,773 Yes 0
93.837 Cardiovascular Diseases Research $1,500 Yes 0
93.788 Opioid Str $356 - 0
20.600 State and Community Highway Safety $69 - 0

Contacts

Name Title Type
KCBGNFJGK478 Kim McCarthy Auditee
7343430830 Melissa Jagst Auditor
No contacts on file

Notes to SEFA

Title: Expenditures and Other Reporting Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the Schedule or SEFA) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Corporations consolidated financial statements include, for the year ended June 30, 2022, the operations of Saint Josephs Tower, Inc. ("Tower"), a subsidiary of Trinity Continuing Care Services. Tower reported total expenditures of federal awards of $3,491,706 for the year ended June 30, 2022.Included in these total expenditures is $2,889,471, which represents the outstanding mortgage balances insured under the Federal Housing Administrations ("FHA") Section 202 Supportive Housing for the Elderly. In addition, Tower earned $602,235 of its revenues in the year ended June 30, 2022 from the U.S. Department of Housing and Urban Development under the terms of the Housing Assistance Payment contracts. The accompanying consolidated SEFA does not include the federal awards activity of Tower because the federal expenditures were included in a separate audit report in accordance with the Uniform Guidance. The Corporations consolidated financial statements include the operations of Saint Josephs Mercy Care Services, Inc. (SJMCS) for the year ended June 30, 2022. SJMCS reported total expenditures of federal awards of $13,325,720 for the year ended June 30, 2022. The accompanying SEFA does not include the federal award activity of SJMCS because the federal expenditures were included in a separate audit report in accordance with the Uniform Guidance.
Title: Commitments and Contingencies Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the Schedule or SEFA) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Corporation participates in numerous state and federal grant programs, which are governed by variousrules and regulations of the grantor agencies. Costs charged to the respective grant programs are subject toaudit and adjustments by the grantor agencies. While the Corporation believes it has complied with all ofthe rules and regulations, to the extent that the Corporation has not complied with rules and regulationsgoverning the grants, refund of any money received may be required and the collectability of any relatedreceivable at June 30, 2022, may be impaired.
Title: Loan Programs Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the Schedule or SEFA) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Corporations consolidated financial statements include the operations of Trinity Health Of New England, Inc. (THOFNE) for the year ended June 30, 2022. THOFNE recorded total expenditures of federal awards of $60,054,411 for the year ended June 30, 2022. Included in these total expenditures is$11,339,495, which represents expenditures of Sisters of Providence Health System. THOFNE's fiscal year end is September 30 and THOFNEs consolidated financial statements and Schedule of Federal Expenditures will be audited separately for the year ended September 30, 2022.Accordingly, the federal expenditures were included in a separate audit report in accordance with the Uniform Guidance. The loan program listed below is administered directly by the Corporation. The balance relating to this program is included in the Corporations consolidated financial statements. ALN Number Program Name Outstanding Balance at June 30, 202293.364 Nursing Student Loan $272,062
Title: Provider Relief Funds Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the Schedule or SEFA) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Provider Relief Funds included in the Schedule were received by the following entities (legal name and tax identification number): Mount St. Joseph 01-0274998; St. Mary Home, Incorporated 06-0646843; McAuley Center, Incorporated 06-1058086; Sunnyview Hospital And Rehabilitation Center 14-1338386, Samaritan Hospital Of Troy, New York 14-1338544; St. Peter's Hospital Of The City Of Albany 14-1348692; Villa Mary Immaculate 14-1438749; Capital Region Geriatric Center, Inc. 14-1701597; Beverwyck, Inc. 14-1717028; Heritage House Nursing Center, Inc. 14-1725101; Our Lady Of Mercy Life Center 14-1743506; Seton Health At Schuyler Ridge Residential Healthcare 14-1756230; The Marjorie Doyle Rockwell Center, Inc. 14-1793885; Glen Eddy, Inc. 14-1794150; St. Joseph's Hospital Health Center 15-0532254; Franciscan Health Support, Inc. 16-1236354; Probility Therapy Services 20-2020239; Nazareth Physician Services, Inc. 20-3261266; The James A. Eddy Memorial Geriatric Center, Inc. 22-2570478; St. Francis Medical Center, A New Jersey Nonprofit Corporation 22-3431049; Mercy Home Health 23-1352099; Mercy Catholic Medical Center Of Southeastern Pennsylvania 23-1352191; St. Mary Medical Center 23-1913910; Langhorne Physician Services, Inc. 23-2571699; Nazareth Hospital 23-2794121; The Ambulatory Surgery Center At St. Mary 23-2871206; Mercy Life Center Corporation 25-1604115; Good Samaritan Hospital, Inc. 26-1720984; St. Mary's Medical Group, Inc. 26-1858563; Saint Alphonsus Medical Center - Ontario, Inc. 27-1789847; Saint Alphonsus Medical Center - Baker City, Inc. 27-1790052; Advantage Health/Saint Mary's Medical Group 27-2491974; St. Joseph's Medical, P.C. 27-3899821; Mercy Health Services - Iowa, Corp. 31-1373080; Mount Carmel Health Providers, Inc. 31-1382442; Mount Carmel Health System 31-1439334; Diley Ridge Medical Center 34-2032340; Saint Joseph Regional Medical Center - South Bend Campus, Inc. 35-0868157; Saint Joseph Regional Medical Center, Inc. 35-1568821; Mercy Hospital And Medical Center 36-2170152; Gottlieb Memorial Hospital 36-2379649; Gottlieb Community Health Services Corporation 36-3332852; Loyola University Medical Center 36-4015560; Glacier Hills Inc 38-1891500; Catherine Mcauley Health Services Corporation 38-2507173; Trinity Continuing Care Services 38-2559656; Mercy Health Partners (Dba Mercy Health Muskegon) 38-2589966; Mercy Services For Aging Nonprofit Housing Corporation 38-2719605; IHA Health Services Corporation 38-3316559; St. Peter's Health Partners Medical Associates, P.C. 46-1177336; St. Mary Emergency Medical Services 46-5354512; Trinity Health PACE 47-3073124; St. Francis Hospital, Inc. 51-0064326; Holy Cross Health, Inc. 52-0738041; St. Joseph Of The Pines, Inc. 56-0694200; St. Mary's Health Care System, Inc. 58-0566223; Holy Cross Hospital, Inc. 59-0791028; Hawthorne Ridge, Inc. 80-0102840; Saint Alphonsus Regional Medical Center, Inc. 82-0200895; Saint Alphonsus Medical Center - Nampa, Inc. 82-0200896; Trinity Continuing Care Services - Massachusetts 82-4005577; St. Francis Medical Associates, Pa 83-2199054; Trinity Continuing Care Services - Indiana, Inc. 93-0907047

Finding Details

Finding 2022-007
Condition ?The Corporation included expenses, at most totaling $21,338, that are not allowed under the criteria for Provider Relief Funds Skilled Nursing Facility Infection Control (?SNF?) funding, as dictated by the 2022 2 CFR Part 200 Compliance Supplement (?Compliance Supplement?). Criteria ? Per the Compliance Supplement, SNF funds may only be used to reimburse recipients for costs associated with administering COVID-19 testing, reporting COVID-19 tests results to local, state, and federal governments, hiring staff to provide patient care or administrative support, expenses incurred to improve infection control, or providing additional services to residents. Cause ? There were two expenditure selections that were recorded for the purchase of bulk food items that did not qualify as allowable activities under the grant. In the identified instances of noncompliance, these expenditures were recorded in the incorrect cost center and should not have been applied to the grants as SNF expenses eligible for reimbursement. Effect ? Consequences for failure to comply with grant conditions may include a reduction of overall award. Questioned costs ? None Context ? Two out of forty-two selections were improperly included as SNF expenditures. Repeat Finding from Prior Year ? No Recommendation? Management should institute formal policies and procedures to ensure grant related expenditure support is reviewed in more detail before including expenditures on in the HHS portal and on the consolidated SEFA.
Finding 2022-008
Condition ? In order for a claim related to COVID-19 testing, testing-related items, or COVID-19 treatment to be eligible for reimbursement and inclusion on the Schedule of Expenditures of Federal Awards (?SEFA?), the individuals must not have any health care coverage at the time services were rendered. As part of the Add and Attest to Patient Roster Step within the claim submission process, providers must attest to the following: ?if you have direct contact with the patient, you should make best efforts to confirm that the patient was uninsured at the time the services were provided?? The Corporation made its best efforts and followed all its policies to determine that the patients did not have insurance. Two claim selections included in the SEFA were for services provided to individuals who had health care insurance at the time services were rendered. After it was identified the individuals had health care insurance, refunds to the Health Resources and Services Administration (?HRSA?) were delayed. Criteria ? The Uniform Grant Guidance Compliance Supplement Addendum states, ?Services must be for individuals who at the time services were provided were uninsured as described in the terms and conditions of the award.? Cause ? Two claims were improperly submitted for reimbursement under the program when the patients had active insurance at the time of service and such information was available to Trinity Health at the time of billing. Both instances were caused by failure to address double payments for the same expenses made by HRSA and subsequently by insurance providers in a timely manner. Effect ? Claims were submitted for reimbursement under the uninsured program that were subsequently determined to no longer be eligible for reimbursement. Refunds were not issued to HRSA on a timely basis and were only issued due to the two claims being selected for purposes of the single audit testing. Questioned costs ? None Context ? Two out of 60 claims in our sample included patients who had commercial insurance at the time of service. Refunds were not issued to HRSA on a timely basis. Repeat Finding from Prior Year ? Yes. In the prior year, there were three instances of refunds not being issued to HRSA on a timely basis. Recommendation ? The federal government ended the COVID Uninsured Testing grant program in 2022. However, for similar programs in the future, program administrators should review eligibility documentation for each claim prior to submitting claims for reimbursement. Program administrators should additionally review accounts that received HRSA reimbursements and check if refunds are needed. They should also review refunds needing to be made to ensure they are occurring in a timely manner.
Finding 2022-005
Condition ?The Corporation recorded fringe benefits for a grant employee at an incorrect amount. As a result, the Corporation understated expenditures on the SEFA by $200 for the year ended June 30, 2022. Criteria ? 2 CFR Part 200.1 states an improper payment means any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements. Cause ? There was one fringe benefits expenditure selection that was recorded at the incorrect amount due to a manual error in the calculation of benefits allocated to the grant. In the identified instance of non-compliance, the fringe expense recorded was inconsistent with the amount of salary paid to the individual and the assigned fringe rate. The expenditure should not have been approved as entered after the review process. Effect ? Consequences for failure to comply with grant conditions may include a reduction of overall award and/or a restriction or reduction in future awards. Questioned costs ? None Context ? One out of forty expenditure selections was understated in the consolidated SEFA and the related payment by the granting agency was understated as well. Repeat Finding from Prior Year ? No Recommendation? Management should institute formal policies and procedures to ensure grant related expenditure support is reviewed in more detail and reported at the correct amount.
Finding 2022-006
Condition ?The Corporation provided services funded by the Centers for Disease Control and Prevention (CDC) through the National Diabetes Prevention Program (NDPP) to individuals who did not qualify for the program. Criteria ? Per the CDC, in order to be eligible to participate in the NDPP, individuals must meet all of the following criteria: 18 years or older, Body Mass Index (BMI) over 25, not diagnosed with Type 1 or Type 2 Diabetes, and not currently pregnant. In addition, the individual must meet at least one of the following conditions: diagnosed with prediabetes, previously diagnosed with gestational diabetes, or achieve a high-risk result on prediabetes risk test. Cause ? There was one selected participant that did not meet the necessary requirements to be enrolled in the program and therefore was not an eligible participant. In the identified instance of non-compliance, the participant did not meet the BMI requirement to be enrolled in the program. The participant should have been removed from the program upon review of the eligibility criteria. Effect ? Consequences for failure to comply with grant conditions may include a reduction of overall award and/or a restriction or reduction in future awards. Questioned costs ? None Context ? One out of forty participants selected was not eligible for the program. After further review of data that included all program participants (1,606 participants), it was determined that a total of 15 individuals who participated in the program were not eligible under the requirements of the grant. Repeat Finding from Prior Year ? No Recommendation? Management should institute formal policies and procedures to ensure only eligible participants are participating in the program.
Finding 2022-001
Condition ? Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the Common Origination and Disbursement (COD) System on an ongoing basis. There are two types of reconciliation that can be performed separately or simultaneously during the month: 1) Internal Reconciliation - the business and financial aid offices compare the monthly financial aid office roster for scheduled and actual disbursements in each office?s system to a monthly business office cash detail report that reflects funds drawn down and funds disbursed each month;2) External Reconciliation ? Institutions compare their reconciled internal records to the Department of Education?s records of funds received and returned, and loans originated and disbursed. Mount Carmel College of Nursing (?the College?) performed monthly a reconciliation process only for loan disbursement records between the student financial aid system at the financial aid office and the Department?s COD System. It appears that the College failed to complete reconciliation for disbursement records within the student financial aid system at the financial aid office and the accounting system at the business office. Additionally, there was no reconciliation procedure performed for cash activities among the College?s student financial aid system, accounting system, and Department of Education?s COD System. Criteria ? The Uniform Grant Guidance Compliance Supplement Direct Loan Reconciliation requirement states, ?Each month, COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records.? Cause ? The College?s student financial aid administration lacks understanding about the Direct Loan reconciliation process and knowledge about SAS data files. Effect ? The College failed to complete the monthly Direct Loan reconciliation in conformity with regulatory requirements. This potentially leads to the College not being able to timely identify and resolve discrepancies that exist among financial aid, business office, and COD records. Questioned costs ? None Context ? The College did not complete this requirement for the entire fiscal year, resulting in 12 reconciliations that were not performed. Repeat Finding from Prior Year ? No Recommendation ? The College?s Student Financial Aid administration shall consult with Direct Loan reconciliation regulatory guidance as illustrated in Federal Student Aid Handbook Volume 4 Chapter 6 and develop the monthly Direct Loan reconciliation process that is compatible with the College?s Direct Loan program operations. Additionally, respective controls shall be placed surrounding these processes to ensure that all records are reconciled, and discrepancies are resolved in a timely manner.
Finding 2022-002
Condition ? Mount Carmel College of Nursing (?the College?) administers HEERF Institutional Aid Portion under the reimbursement payment method. The reimbursement payment method requires that the College must disburse funds for HEERF program purposes before requesting payments from the federal awarding agency or pass-through entity. The College followed this reimbursing principle for the most part. However, it was discovered that there were 10 disbursements in March and April of 2022 didn?t occur until after the federal payment was received. Criteria ? The Uniform Grant Guidance Compliance Supplement Cash Management general requirement states, ?Under the reimbursement payment method, program costs must be paid by non-federal entity funds before submitting a payment request.? Cause ? The only personnel who was granted access to G5 for drawdown requests resigned in April of 2022. As a result, that personnel requested an advance payment for the remaining available funds prior to departure in anticipation that the funds would be disbursed in full. Effect ? Ten selections were disbursed after the drawdown date. The total questioned cost resulting from these 10 delayed disbursements is $390,053. Although none of the disbursements were deemed to be unreasonable for program purposes, these 10 transactions were identified to be in violation of the Cash Management requirement for reimbursement payment method. Questioned costs ? $390,053 Context ? Ten out of a total of 57 selected transactions were disbursed after the drawdown date. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration shall provide proper training and exercise oversight to employees who are involved with administering HEERF disbursements. Appropriate levels of review shall also be performed by personnel with knowledge and background of federal spending requirements and other statutory regulations outlined in the program agreement.
Finding 2022-003
Condition ? St. Joseph?s Hospital College of Nursing (?the College?) administers HEERF Institutional Aid Portion under the reimbursement payment method. However, The College requested reimbursements based on the billing dates rather than actual payment dates. The reimbursement payment method requires that the College must disburse funds for HEERF program purposes before requesting payments from the federal awarding agency or passthrough entity. It was discovered that 6 invoices were not paid until after the federal payment was received. Criteria ? The Uniform Grant Guidance Compliance Supplement Cash Management general requirement states, ?Under the reimbursement payment method, program costs must be paid by non-federal entity funds before submitting a payment request.? Cause ? The College?s business administration drew down funding for costs eligible for reimbursement that were incurred and/or approved expenditures but not paid. Effect ? Six transactions had delayed disbursements, resulting in questioned costs of $158,701. Although none of the disbursements were deemed to be unreasonable for program purposes, these 6 transactions were identified to be in violation of the Cash Management requirement for reimbursement payment method. Questioned costs ? $158,701 Context ? Six out of 40 selected transactions were paid after the drawdown date. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration shall provide proper training and exercise oversight to employees who are involved with administering HEERF disbursements. Appropriate levels of review shall also be performed by personnel with knowledge and background of federal spending requirements and other statutory regulations outlined in the program agreement.
Finding 2022-004
Condition ? As directed by the U.S. Department of Education for all HEERF funding, Mount Carmel College of Nursing (?the College?) is required to prepare quarterly reports for Institutional portions and conspicuously post them on the College?s website in a timely manner. During the audit it was determined that the College did not complete quarterly reports for Q3 and Q4 for fiscal year ending June 30, 2022, for HEERF Institutional portions of funding and hence no public postings were made available on the College?s website. Criteria ? The U.S. Department of Education, under sections 2 CFR 200.328 and 2 CFR 200.329, requires that each quarterly reporting form for both HEERF Institutional and Student Aid Portion must be completed and posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Cause ? The Senior Finance Director (report preparer) and Director of Financial Aid (report reviewer) for the College both resigned in March 2022 and April 2022, respectively. As a result, the quarterly reports were not prepared within the required timeframe. Effect ? Neither the Institutional nor Student Aid Portion quarterly reporting forms were prepared and posted for Q3 and Q4 of the current fiscal year. This results in noncompliance and could cause a negative impact on future fundings for the College. Questioned costs ? $0 Context ? Two out of four quarterly reports for the fiscal year ended June 30, 2022 were not completed. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration should have a plan in place to ensure that quarterly reports are prepared timely and have backup plans in place in the event that the preparer or reviewer are not available.
Finding 2022-007
Condition ?The Corporation included expenses, at most totaling $21,338, that are not allowed under the criteria for Provider Relief Funds Skilled Nursing Facility Infection Control (?SNF?) funding, as dictated by the 2022 2 CFR Part 200 Compliance Supplement (?Compliance Supplement?). Criteria ? Per the Compliance Supplement, SNF funds may only be used to reimburse recipients for costs associated with administering COVID-19 testing, reporting COVID-19 tests results to local, state, and federal governments, hiring staff to provide patient care or administrative support, expenses incurred to improve infection control, or providing additional services to residents. Cause ? There were two expenditure selections that were recorded for the purchase of bulk food items that did not qualify as allowable activities under the grant. In the identified instances of noncompliance, these expenditures were recorded in the incorrect cost center and should not have been applied to the grants as SNF expenses eligible for reimbursement. Effect ? Consequences for failure to comply with grant conditions may include a reduction of overall award. Questioned costs ? None Context ? Two out of forty-two selections were improperly included as SNF expenditures. Repeat Finding from Prior Year ? No Recommendation? Management should institute formal policies and procedures to ensure grant related expenditure support is reviewed in more detail before including expenditures on in the HHS portal and on the consolidated SEFA.
Finding 2022-008
Condition ? In order for a claim related to COVID-19 testing, testing-related items, or COVID-19 treatment to be eligible for reimbursement and inclusion on the Schedule of Expenditures of Federal Awards (?SEFA?), the individuals must not have any health care coverage at the time services were rendered. As part of the Add and Attest to Patient Roster Step within the claim submission process, providers must attest to the following: ?if you have direct contact with the patient, you should make best efforts to confirm that the patient was uninsured at the time the services were provided?? The Corporation made its best efforts and followed all its policies to determine that the patients did not have insurance. Two claim selections included in the SEFA were for services provided to individuals who had health care insurance at the time services were rendered. After it was identified the individuals had health care insurance, refunds to the Health Resources and Services Administration (?HRSA?) were delayed. Criteria ? The Uniform Grant Guidance Compliance Supplement Addendum states, ?Services must be for individuals who at the time services were provided were uninsured as described in the terms and conditions of the award.? Cause ? Two claims were improperly submitted for reimbursement under the program when the patients had active insurance at the time of service and such information was available to Trinity Health at the time of billing. Both instances were caused by failure to address double payments for the same expenses made by HRSA and subsequently by insurance providers in a timely manner. Effect ? Claims were submitted for reimbursement under the uninsured program that were subsequently determined to no longer be eligible for reimbursement. Refunds were not issued to HRSA on a timely basis and were only issued due to the two claims being selected for purposes of the single audit testing. Questioned costs ? None Context ? Two out of 60 claims in our sample included patients who had commercial insurance at the time of service. Refunds were not issued to HRSA on a timely basis. Repeat Finding from Prior Year ? Yes. In the prior year, there were three instances of refunds not being issued to HRSA on a timely basis. Recommendation ? The federal government ended the COVID Uninsured Testing grant program in 2022. However, for similar programs in the future, program administrators should review eligibility documentation for each claim prior to submitting claims for reimbursement. Program administrators should additionally review accounts that received HRSA reimbursements and check if refunds are needed. They should also review refunds needing to be made to ensure they are occurring in a timely manner.
Finding 2022-005
Condition ?The Corporation recorded fringe benefits for a grant employee at an incorrect amount. As a result, the Corporation understated expenditures on the SEFA by $200 for the year ended June 30, 2022. Criteria ? 2 CFR Part 200.1 states an improper payment means any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements. Cause ? There was one fringe benefits expenditure selection that was recorded at the incorrect amount due to a manual error in the calculation of benefits allocated to the grant. In the identified instance of non-compliance, the fringe expense recorded was inconsistent with the amount of salary paid to the individual and the assigned fringe rate. The expenditure should not have been approved as entered after the review process. Effect ? Consequences for failure to comply with grant conditions may include a reduction of overall award and/or a restriction or reduction in future awards. Questioned costs ? None Context ? One out of forty expenditure selections was understated in the consolidated SEFA and the related payment by the granting agency was understated as well. Repeat Finding from Prior Year ? No Recommendation? Management should institute formal policies and procedures to ensure grant related expenditure support is reviewed in more detail and reported at the correct amount.
Finding 2022-006
Condition ?The Corporation provided services funded by the Centers for Disease Control and Prevention (CDC) through the National Diabetes Prevention Program (NDPP) to individuals who did not qualify for the program. Criteria ? Per the CDC, in order to be eligible to participate in the NDPP, individuals must meet all of the following criteria: 18 years or older, Body Mass Index (BMI) over 25, not diagnosed with Type 1 or Type 2 Diabetes, and not currently pregnant. In addition, the individual must meet at least one of the following conditions: diagnosed with prediabetes, previously diagnosed with gestational diabetes, or achieve a high-risk result on prediabetes risk test. Cause ? There was one selected participant that did not meet the necessary requirements to be enrolled in the program and therefore was not an eligible participant. In the identified instance of non-compliance, the participant did not meet the BMI requirement to be enrolled in the program. The participant should have been removed from the program upon review of the eligibility criteria. Effect ? Consequences for failure to comply with grant conditions may include a reduction of overall award and/or a restriction or reduction in future awards. Questioned costs ? None Context ? One out of forty participants selected was not eligible for the program. After further review of data that included all program participants (1,606 participants), it was determined that a total of 15 individuals who participated in the program were not eligible under the requirements of the grant. Repeat Finding from Prior Year ? No Recommendation? Management should institute formal policies and procedures to ensure only eligible participants are participating in the program.
Finding 2022-001
Condition ? Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). A school should reconcile all cash (drawdowns and refunds of cash) and disbursement records (actual disbursements and adjustments) with information in the Common Origination and Disbursement (COD) System on an ongoing basis. There are two types of reconciliation that can be performed separately or simultaneously during the month: 1) Internal Reconciliation - the business and financial aid offices compare the monthly financial aid office roster for scheduled and actual disbursements in each office?s system to a monthly business office cash detail report that reflects funds drawn down and funds disbursed each month;2) External Reconciliation ? Institutions compare their reconciled internal records to the Department of Education?s records of funds received and returned, and loans originated and disbursed. Mount Carmel College of Nursing (?the College?) performed monthly a reconciliation process only for loan disbursement records between the student financial aid system at the financial aid office and the Department?s COD System. It appears that the College failed to complete reconciliation for disbursement records within the student financial aid system at the financial aid office and the accounting system at the business office. Additionally, there was no reconciliation procedure performed for cash activities among the College?s student financial aid system, accounting system, and Department of Education?s COD System. Criteria ? The Uniform Grant Guidance Compliance Supplement Direct Loan Reconciliation requirement states, ?Each month, COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records.? Cause ? The College?s student financial aid administration lacks understanding about the Direct Loan reconciliation process and knowledge about SAS data files. Effect ? The College failed to complete the monthly Direct Loan reconciliation in conformity with regulatory requirements. This potentially leads to the College not being able to timely identify and resolve discrepancies that exist among financial aid, business office, and COD records. Questioned costs ? None Context ? The College did not complete this requirement for the entire fiscal year, resulting in 12 reconciliations that were not performed. Repeat Finding from Prior Year ? No Recommendation ? The College?s Student Financial Aid administration shall consult with Direct Loan reconciliation regulatory guidance as illustrated in Federal Student Aid Handbook Volume 4 Chapter 6 and develop the monthly Direct Loan reconciliation process that is compatible with the College?s Direct Loan program operations. Additionally, respective controls shall be placed surrounding these processes to ensure that all records are reconciled, and discrepancies are resolved in a timely manner.
Finding 2022-002
Condition ? Mount Carmel College of Nursing (?the College?) administers HEERF Institutional Aid Portion under the reimbursement payment method. The reimbursement payment method requires that the College must disburse funds for HEERF program purposes before requesting payments from the federal awarding agency or pass-through entity. The College followed this reimbursing principle for the most part. However, it was discovered that there were 10 disbursements in March and April of 2022 didn?t occur until after the federal payment was received. Criteria ? The Uniform Grant Guidance Compliance Supplement Cash Management general requirement states, ?Under the reimbursement payment method, program costs must be paid by non-federal entity funds before submitting a payment request.? Cause ? The only personnel who was granted access to G5 for drawdown requests resigned in April of 2022. As a result, that personnel requested an advance payment for the remaining available funds prior to departure in anticipation that the funds would be disbursed in full. Effect ? Ten selections were disbursed after the drawdown date. The total questioned cost resulting from these 10 delayed disbursements is $390,053. Although none of the disbursements were deemed to be unreasonable for program purposes, these 10 transactions were identified to be in violation of the Cash Management requirement for reimbursement payment method. Questioned costs ? $390,053 Context ? Ten out of a total of 57 selected transactions were disbursed after the drawdown date. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration shall provide proper training and exercise oversight to employees who are involved with administering HEERF disbursements. Appropriate levels of review shall also be performed by personnel with knowledge and background of federal spending requirements and other statutory regulations outlined in the program agreement.
Finding 2022-003
Condition ? St. Joseph?s Hospital College of Nursing (?the College?) administers HEERF Institutional Aid Portion under the reimbursement payment method. However, The College requested reimbursements based on the billing dates rather than actual payment dates. The reimbursement payment method requires that the College must disburse funds for HEERF program purposes before requesting payments from the federal awarding agency or passthrough entity. It was discovered that 6 invoices were not paid until after the federal payment was received. Criteria ? The Uniform Grant Guidance Compliance Supplement Cash Management general requirement states, ?Under the reimbursement payment method, program costs must be paid by non-federal entity funds before submitting a payment request.? Cause ? The College?s business administration drew down funding for costs eligible for reimbursement that were incurred and/or approved expenditures but not paid. Effect ? Six transactions had delayed disbursements, resulting in questioned costs of $158,701. Although none of the disbursements were deemed to be unreasonable for program purposes, these 6 transactions were identified to be in violation of the Cash Management requirement for reimbursement payment method. Questioned costs ? $158,701 Context ? Six out of 40 selected transactions were paid after the drawdown date. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration shall provide proper training and exercise oversight to employees who are involved with administering HEERF disbursements. Appropriate levels of review shall also be performed by personnel with knowledge and background of federal spending requirements and other statutory regulations outlined in the program agreement.
Finding 2022-004
Condition ? As directed by the U.S. Department of Education for all HEERF funding, Mount Carmel College of Nursing (?the College?) is required to prepare quarterly reports for Institutional portions and conspicuously post them on the College?s website in a timely manner. During the audit it was determined that the College did not complete quarterly reports for Q3 and Q4 for fiscal year ending June 30, 2022, for HEERF Institutional portions of funding and hence no public postings were made available on the College?s website. Criteria ? The U.S. Department of Education, under sections 2 CFR 200.328 and 2 CFR 200.329, requires that each quarterly reporting form for both HEERF Institutional and Student Aid Portion must be completed and posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Cause ? The Senior Finance Director (report preparer) and Director of Financial Aid (report reviewer) for the College both resigned in March 2022 and April 2022, respectively. As a result, the quarterly reports were not prepared within the required timeframe. Effect ? Neither the Institutional nor Student Aid Portion quarterly reporting forms were prepared and posted for Q3 and Q4 of the current fiscal year. This results in noncompliance and could cause a negative impact on future fundings for the College. Questioned costs ? $0 Context ? Two out of four quarterly reports for the fiscal year ended June 30, 2022 were not completed. Repeat Finding from Prior Year ? No Recommendation ? The College?s business administration should have a plan in place to ensure that quarterly reports are prepared timely and have backup plans in place in the event that the preparer or reviewer are not available.