Finding 2022-001 ? Activities Allowed or Unallowed and Eligibility Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 HRSA COVID-19 Claims Reimbursement for the Uninsured and the COVID-19 Coverage Assistance Fund Federal Award Numbers: Various Federal Award Period of Performance: September 1, 2021 to April 5, 2022 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: As part of our testing of the Company?s internal control over allowability as it relates to all accounts identified with a potential COVID-19 account billing indicator that are subsequently reviewed by the Company to determine whether the account can be billed to the HRSA COVID-19 Claims Reimbursement for the Uninsured program, we identified a population of accounts that were improperly excluded from the review for the period September 1, 2021 to December 31, 2021. Cause: The original script to capture potential accounts for the HRSA COVID-19 Claims Reimbursement for the Uninsured program did not include accounts that had a zero balance and/or were in a closed status. Effect or potential effect: Accounts existed that might have been able to be billed to the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Questioned costs: None. Context: Forty accounts were sampled from a population of 20,706 accounts identified with a potential COVID-19 account billing indicator. For 12 (30%) of the 40 accounts sampled, although the account was identified with a potential COVID-19 account billing indicator, the account was excluded from further review for potential billing to the HRSA COVID-19 Claims Reimbursement for the Uninsured program. These accounts were either related to the Company?s HealthLab financial assistance scoring or the patient was previously approved for Company financial assistance, and so these accounts were adjusted off to financial assistance shortly after the account qualified for billing. It was determined that a total of 2,098 (10.13%) accounts were excluded from the Company?s HRSA review for the period September 1, 2021 to December 31, 2021, and, of these 2,098 accounts, 1,898 (90.47%) related to lab accounts that averaged $165 to $190 in gross charges. Federal expenditures for Assistance Listing 93.461 totaled $2,907,040 for the year ended August 31, 2022. Identification as a repeat finding, if applicable: The finding is a repeat of finding 2021-001 from the prior year. Recommendation: The Company should ensure that review controls are properly designed. Views of responsible officials: In response to the prior-year finding, and after the fiscal year ended August 31, 2021, the Company redesigned its allowability review control to include these previously omitted accounts, as applicable and subject to timely claim filing requirements. The corrective action plan was completed and in place by December 31, 2021, shortly after the FY20 Uniform Guidance audit was completed on November 29, 2021. The HRSA COVID-19 Claims Reimbursement for the Uninsured program ceased to accept claims for testing and treatment effective March 22, 2022, and claims for vaccination were no longer accepted after April 5, 2022. Therefore, no further remediation is required at this time.
Finding 2022-002 ? Reporting Identification of the federal program: Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Provider Relief Fund Reporting Entity: Northwestern Memorial HealthCare Group Tax Identification Number (TIN): 364724966 Period of Availability: 01/01/2020?06/30/2022 (Period 3) 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).? The terms and conditions of the award require the recipient to submit reports as the secretary of HHS determines are needed to ensure compliance with the conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: The amounts reported for net patient service revenue (NPSR) by payer for calendar year 2022 Quarter 1 (Q1 2022) and Quarter 2 (Q2 2022) were incorrect for Commercial Insurance and Medicare A+B for Northwestern Memorial HealthCare Group TIN?s Period 3 Provider Relief Fund (PRF) Report. Cause: Management?s review of out-of-period adjustments made to NPSR was not sufficiently precise to detect that the incorrect amounts were included in management?s lost revenue calculation workbook used to prepare the Period 3 PRF Report for Northwestern Memorial HealthCare Group?s reporting TIN. Effect or potential effect: NPSR by payer was incorrectly reported for Q1 2022 and Q2 2022 for Commercial Insurance and Medicare A+B. The total NPSR was correct as reported, and there was no impact on resulting lost revenues. Questioned costs: None. Context: We tested five of 10 Periods 2 and 3 PRF Reports submitted to HRSA. For one of the five reports tested, the NPSR amounts reported by payer for two of the six financial classes were incorrect for Q1 2022 and Q2 2022 for Northwestern Memorial HealthCare Group?s reporting TIN as follows: Total Revenue/Net Changes from Patient Care (2022 Actuals) ? As Reported (See Schedule of Findings and Questioned Costs for chart/table) Total Revenue/Net Changes from Patient Care (2022 Actuals) ? Corrected (See Schedule of Findings and Questioned Costs for chart/table) Total Revenue/Net Changes from Patient Care (2022 Actuals) ? Increase/(Decrease) (See Schedule of Findings and Questioned Costs for chart/table) There was no impact on lost revenues reported for these quarters. Federal expenditures for Assistance Listing 93.498 totaled $199,865,192 for the year ended August 31, 2022. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The Company should ensure that internal controls over the review of PRF Reports are enhanced to include sufficient precision to allow for accurate reporting of NPSR by payer. Views of responsible officials: While there was no impact on lost revenues reported in the Northwestern Memorial HealthCare Group?s TIN Period 3 PRF Report, we agree that the amounts used for out-of-period adjustments were incorrect. Going forward, we will provide additional peer review of PRF Reports to confirm accuracy.
Finding 2022-001 ? Activities Allowed or Unallowed and Eligibility Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 HRSA COVID-19 Claims Reimbursement for the Uninsured and the COVID-19 Coverage Assistance Fund Federal Award Numbers: Various Federal Award Period of Performance: September 1, 2021 to April 5, 2022 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: As part of our testing of the Company?s internal control over allowability as it relates to all accounts identified with a potential COVID-19 account billing indicator that are subsequently reviewed by the Company to determine whether the account can be billed to the HRSA COVID-19 Claims Reimbursement for the Uninsured program, we identified a population of accounts that were improperly excluded from the review for the period September 1, 2021 to December 31, 2021. Cause: The original script to capture potential accounts for the HRSA COVID-19 Claims Reimbursement for the Uninsured program did not include accounts that had a zero balance and/or were in a closed status. Effect or potential effect: Accounts existed that might have been able to be billed to the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Questioned costs: None. Context: Forty accounts were sampled from a population of 20,706 accounts identified with a potential COVID-19 account billing indicator. For 12 (30%) of the 40 accounts sampled, although the account was identified with a potential COVID-19 account billing indicator, the account was excluded from further review for potential billing to the HRSA COVID-19 Claims Reimbursement for the Uninsured program. These accounts were either related to the Company?s HealthLab financial assistance scoring or the patient was previously approved for Company financial assistance, and so these accounts were adjusted off to financial assistance shortly after the account qualified for billing. It was determined that a total of 2,098 (10.13%) accounts were excluded from the Company?s HRSA review for the period September 1, 2021 to December 31, 2021, and, of these 2,098 accounts, 1,898 (90.47%) related to lab accounts that averaged $165 to $190 in gross charges. Federal expenditures for Assistance Listing 93.461 totaled $2,907,040 for the year ended August 31, 2022. Identification as a repeat finding, if applicable: The finding is a repeat of finding 2021-001 from the prior year. Recommendation: The Company should ensure that review controls are properly designed. Views of responsible officials: In response to the prior-year finding, and after the fiscal year ended August 31, 2021, the Company redesigned its allowability review control to include these previously omitted accounts, as applicable and subject to timely claim filing requirements. The corrective action plan was completed and in place by December 31, 2021, shortly after the FY20 Uniform Guidance audit was completed on November 29, 2021. The HRSA COVID-19 Claims Reimbursement for the Uninsured program ceased to accept claims for testing and treatment effective March 22, 2022, and claims for vaccination were no longer accepted after April 5, 2022. Therefore, no further remediation is required at this time.
Finding 2022-002 ? Reporting Identification of the federal program: Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Provider Relief Fund Reporting Entity: Northwestern Memorial HealthCare Group Tax Identification Number (TIN): 364724966 Period of Availability: 01/01/2020?06/30/2022 (Period 3) 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).? The terms and conditions of the award require the recipient to submit reports as the secretary of HHS determines are needed to ensure compliance with the conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: The amounts reported for net patient service revenue (NPSR) by payer for calendar year 2022 Quarter 1 (Q1 2022) and Quarter 2 (Q2 2022) were incorrect for Commercial Insurance and Medicare A+B for Northwestern Memorial HealthCare Group TIN?s Period 3 Provider Relief Fund (PRF) Report. Cause: Management?s review of out-of-period adjustments made to NPSR was not sufficiently precise to detect that the incorrect amounts were included in management?s lost revenue calculation workbook used to prepare the Period 3 PRF Report for Northwestern Memorial HealthCare Group?s reporting TIN. Effect or potential effect: NPSR by payer was incorrectly reported for Q1 2022 and Q2 2022 for Commercial Insurance and Medicare A+B. The total NPSR was correct as reported, and there was no impact on resulting lost revenues. Questioned costs: None. Context: We tested five of 10 Periods 2 and 3 PRF Reports submitted to HRSA. For one of the five reports tested, the NPSR amounts reported by payer for two of the six financial classes were incorrect for Q1 2022 and Q2 2022 for Northwestern Memorial HealthCare Group?s reporting TIN as follows: Total Revenue/Net Changes from Patient Care (2022 Actuals) ? As Reported (See Schedule of Findings and Questioned Costs for chart/table) Total Revenue/Net Changes from Patient Care (2022 Actuals) ? Corrected (See Schedule of Findings and Questioned Costs for chart/table) Total Revenue/Net Changes from Patient Care (2022 Actuals) ? Increase/(Decrease) (See Schedule of Findings and Questioned Costs for chart/table) There was no impact on lost revenues reported for these quarters. Federal expenditures for Assistance Listing 93.498 totaled $199,865,192 for the year ended August 31, 2022. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The Company should ensure that internal controls over the review of PRF Reports are enhanced to include sufficient precision to allow for accurate reporting of NPSR by payer. Views of responsible officials: While there was no impact on lost revenues reported in the Northwestern Memorial HealthCare Group?s TIN Period 3 PRF Report, we agree that the amounts used for out-of-period adjustments were incorrect. Going forward, we will provide additional peer review of PRF Reports to confirm accuracy.