Audit 19423

FY End
2022-06-30
Total Expended
$125.58M
Findings
2
Programs
16
Organization: University of Colorado Health (CO)
Year: 2022 Accepted: 2023-03-09

Organization Exclusion Status:

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Contacts

Name Title Type
ZRLGRD9JDLK8 Dan Rieber Auditee
7205531678 Ryan Sells Auditor
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Notes to SEFA

Title: Noncash Assistance Accounting Policies: The accompanying schedule of expenditures of federal awards ("the Schedule") includes the federal grant activity of University of Colorado Health (UCHealth) under programs of the federal government for the year ended June 30, 2022. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the "Uniform Guidance"). Because the Schedule presents only a selected portion of the operations of UCHealth, it is not intended to and does not present the financial position, changes in net position, or cash flows of UCHealth. Expenditures reported in the Schedule are reported on accrual of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement, except for expenditures related to Assistance Listing Number (ALN) 93.498, Provider Relief Fund and American Rescue Plan (PRF). PRF does not apply the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, but rather applies the U.S. Department of Health and Human Services' (HHS) guidance and frequently asked questions, as outlined in the Compliance Supplement. For the PRF program, HHS has indicated that the amounts on the Schedule should be reported in correspondence with reporting requirements of the HHS PRF Reporting Portal. Payments from HHS for PRF are assigned a payment received period based upon the date each payment from PRF was received. Each period has a specified period of availability and timing of reporting requirements. The pass-through entity identifying numbers are presented where available. UCHealth has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs as allowed under the Uniform Guidance. The Schedule includes Provider Relief Fund receipts under Assistance Listing Number 93.498 for the following entities - see footnotes to the SEFA for chart/table. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The value of the noncash assistance received was determined in accordance with the provisions of the Uniform Guidance. The grantee received $254,668 in noncash assistance during the year ended June 30, 2022 that is included in the schedule of expenditures of federal awards under the U.S. Department of Health and Human Services HIV CARE Formula Grant, ALN 93.917.

Finding Details

ALN, Federal Agency, and Program Name - 93.461, Department of Health and Human Services, Health Resources and Services Administration (HRSA), HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Award Identification Number and Year - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - The terms and conditions of the program allow payment to recipients to provide care or treatment related to positive diagnoses of COVID-19 for uninsured individuals. Condition - UCHealth treated a patient with COVID-19 who did not have insurance at the time of service. The patient subsequently applied for and received coverage under Medicaid, with a retroactive coverage effective date prior to the date of service. UCHealth's process failed to identify the patient's subsequent retroactive insurance coverage, and UCHealth received reimbursement under the program. Questioned Costs - $50,808.16 Identification of How Questioned Costs Were Computed - Questioned costs were determined based on the HRSA funds received for the insured patient. Context - During fiscal year 2022, 60 patients were selected for eligibility testing. Of the 60, 1 patient subsequently applied for and received coverage under Medicaid and, therefore, was not eligible under the program. Cause and Effect - An effective control was not in place to ensure that patients who received treatment were not covered by insurance and, therefore, eligible under the program. This resulted in UCHealth receiving HRSA funds for services provided to a patient who had insurance effective at the time of service. Recommendation - UCHealth should establish a formal process to ensure patients treated under the program do not have insurance coverage at the time of service, including a process to identify patients who subsequently receive insurance coverage that is retroactively effective on the date of service prior to seeking reimbursement under the program. Views of Responsible Officials and Corrective Action Plan - UCHealth reviewed the account in question. Emergency Medicaid was found and attached to the account, and a full refund to HRSA COVID-19 was processed on February 1, 2023 in the amount of $50,808.16 on check #431627. Review of the account demonstrated that system actions identified the correct Medicaid coverage and flagged for manual review. User error was made on consecutive days where Medicaid was not properly added to the account. Financial Counseling and Business Services leadership have reinforced coverage attachment protocols with staff on February 24, 2023.
ALN, Federal Agency, and Program Name - 93.461, Department of Health and Human Services, Health Resources and Services Administration (HRSA), HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Award Identification Number and Year - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - The terms and conditions of the program allow payment to recipients to provide care or treatment related to positive diagnoses of COVID-19 for uninsured individuals. Condition - UCHealth treated a patient with COVID-19 who did not have insurance at the time of service. The patient subsequently applied for and received coverage under Medicaid, with a retroactive coverage effective date prior to the date of service. UCHealth's process failed to identify the patient's subsequent retroactive insurance coverage, and UCHealth received reimbursement under the program. Questioned Costs - $50,808.16 Identification of How Questioned Costs Were Computed - Questioned costs were determined based on the HRSA funds received for the insured patient. Context - During fiscal year 2022, 60 patients were selected for eligibility testing. Of the 60, 1 patient subsequently applied for and received coverage under Medicaid and, therefore, was not eligible under the program. Cause and Effect - An effective control was not in place to ensure that patients who received treatment were not covered by insurance and, therefore, eligible under the program. This resulted in UCHealth receiving HRSA funds for services provided to a patient who had insurance effective at the time of service. Recommendation - UCHealth should establish a formal process to ensure patients treated under the program do not have insurance coverage at the time of service, including a process to identify patients who subsequently receive insurance coverage that is retroactively effective on the date of service prior to seeking reimbursement under the program. Views of Responsible Officials and Corrective Action Plan - UCHealth reviewed the account in question. Emergency Medicaid was found and attached to the account, and a full refund to HRSA COVID-19 was processed on February 1, 2023 in the amount of $50,808.16 on check #431627. Review of the account demonstrated that system actions identified the correct Medicaid coverage and flagged for manual review. User error was made on consecutive days where Medicaid was not properly added to the account. Financial Counseling and Business Services leadership have reinforced coverage attachment protocols with staff on February 24, 2023.