Audit 18976

FY End
2022-06-30
Total Expended
$107.33M
Findings
2
Programs
17
Organization: Christus Health (TX)
Year: 2022 Accepted: 2023-03-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
22741 2022-001 Material Weakness Yes A
599183 2022-001 Material Weakness Yes A

Contacts

Name Title Type
C4A1GH8YACH4 Melissa Crenwelge-Nedbalek Auditee
4692822004 Debra Kohnle Auditor
No contacts on file

Notes to SEFA

Title: Provider Relief Fund Accounting Policies: The accompanying schedule of expenditures of federal and state awards (the Schedule) includesthe federal and state award activity of CHRISTUS Health under programs of the federal and stategovernments for the year ended June 30, 2022. The information in this Schedule is presented inaccordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Uniform Guidance) and the Texas Grant Management Standards (TxGMS). Because the Schedule presents only a selected portion of the operations of CHRISTUS Health, it is not intended to and does not present the financial position, results of operations, changes in net assets, or cash flows of CHRISTUS Health. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the UniformGuidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis indirect cost rate allowed under Uniform Guidance. The Schedule includes grant activity related to the Department of Health and Human Services (HHS) Coronavirus Aid Relief and Economic Security (CARES) Act Assistance Listing Number 93.498. As required based on guidance in the 2022 OMB Compliance Supplement, the Schedule includes all funds received between July 1, 2020 and June 30, 2021 and expended by June 30, 2022 as reported to the Health Resources and Services Administration (HRSA) via the Provider Relief Fund Reporting Portal. CHRISTUS Health did not receive Period 3 funds thus no Period 3 submission was required.
Title: Donated Personal Protective Equipment (unaudited) Accounting Policies: The accompanying schedule of expenditures of federal and state awards (the Schedule) includesthe federal and state award activity of CHRISTUS Health under programs of the federal and stategovernments for the year ended June 30, 2022. The information in this Schedule is presented inaccordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Uniform Guidance) and the Texas Grant Management Standards (TxGMS). Because the Schedule presents only a selected portion of the operations of CHRISTUS Health, it is not intended to and does not present the financial position, results of operations, changes in net assets, or cash flows of CHRISTUS Health. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the UniformGuidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis indirect cost rate allowed under Uniform Guidance. (unaudited) CHRISTUS Health received $183,401 of donated personal protective equipment (PPE) from federal sources for the year ended June 30, 2022. PPE is valued based on fair market value at the time of receipt.
Title: Nature of Activities Accounting Policies: The accompanying schedule of expenditures of federal and state awards (the Schedule) includesthe federal and state award activity of CHRISTUS Health under programs of the federal and stategovernments for the year ended June 30, 2022. The information in this Schedule is presented inaccordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Uniform Guidance) and the Texas Grant Management Standards (TxGMS). Because the Schedule presents only a selected portion of the operations of CHRISTUS Health, it is not intended to and does not present the financial position, results of operations, changes in net assets, or cash flows of CHRISTUS Health. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the UniformGuidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis indirect cost rate allowed under Uniform Guidance. CHRISTUS Health receives various grants to cover costs of specified programs. Finaldetermination of eligibility of costs will be made by the grantors. Should any costs be found ineligible, CHRISTUS Health will be responsible for reimbursing the grantors for these amounts. Additionally, expenditures incurred for various programs may exceed the amounts awarded from the respective pass-through entity or agency. The amounts reported on the Schedule are limited to the award amounts. Amounts in excess of this amount are paid out of non-federal and non-state sources.

Finding Details

Finding 2022-001 ? Internal Control Deficiency Over Activities Allowed or Unallowed Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: January 01, 2020 ? December 31, 2021 Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the 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: CHRISTUS Health (CHRISTUS) did not consistently retain documentation to evidence approval of certain expenses incurred related to COVID-19. Cause: CHRISTUS did not have controls in place to ensure amounts recorded as COVID-19 related expenses were reviewed and approved. Effect or potential effect: Lack of documentation of controls, including review and approval of expenses, may lead to ineligible expenses charged to the program. Questioned Costs: None. Context: We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. CHRISTUS reported $12,991,294 of total expenses for the Period 2 HRSA Portal Submission. Identification as a repeat finding, if applicable: The finding is a repeat finding ? Finding 2021-001. Recommendation: CHRISTUS should refine its process to retain documentation evidencing that each expense recorded to the COVID accounts is reviewed and approved. View of Responsible Officials: Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances. We plan to review our processes related to the retention of expense documentation to improve audit evidence.
Finding 2022-001 ? Internal Control Deficiency Over Activities Allowed or Unallowed Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: January 01, 2020 ? December 31, 2021 Criteria or Specific Requirement (including statutory, regulatory or other citation): Section 200.303 of the 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: CHRISTUS Health (CHRISTUS) did not consistently retain documentation to evidence approval of certain expenses incurred related to COVID-19. Cause: CHRISTUS did not have controls in place to ensure amounts recorded as COVID-19 related expenses were reviewed and approved. Effect or potential effect: Lack of documentation of controls, including review and approval of expenses, may lead to ineligible expenses charged to the program. Questioned Costs: None. Context: We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. CHRISTUS reported $12,991,294 of total expenses for the Period 2 HRSA Portal Submission. Identification as a repeat finding, if applicable: The finding is a repeat finding ? Finding 2021-001. Recommendation: CHRISTUS should refine its process to retain documentation evidencing that each expense recorded to the COVID accounts is reviewed and approved. View of Responsible Officials: Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances. We plan to review our processes related to the retention of expense documentation to improve audit evidence.