Audit 20166

ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19: Provider Relief Fund and American Rescue Plan Rural Distribution (PRF) Federal Award Identification Number and Year - N/A, 2022 Pass-through Entity N/A, Direct funded Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund Distributions and American Rescue Plan Rural Distributions Post Payment Notice of Reporting Requirements dated October 27, 2022, published by the U.S. Department of Health and Human Services (HHS), allowable expenses paid with general and targeted PRF distributions may be reported as a use of PRF funds, provided that the expenses have not been reimbursed by another source. Additionally, per the Health Resources and Services Administration (HRSA) PRF Reporting Portal user guide, "the reporting entity must report the use of these payments by indicating the quarterly expenses reimbursed for these payments" once these expenses have been entered, and the portal will automatically calculate an unreimbursed expense amount for any PRF expenses entered that exceed PRF funding received. As a result of this calculation, the directions from HRSA require users to only input expenses related to the current period's payments in the current portal submission. Condition - The Corporation's controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of expenses. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information Context - The reporting submission for health care expenses did not follow the guidelines published by HHS. The Corporation's Period 2 and Period 3 portal submissions overstated expenses by $3,032,735 and $6,185,506, respectively, that were included within previously submitted portal submission. These expenses should not have been re entered in the Period 2 and Period 3 submissions. Due to the Corporation having excess allowable health care expenses and lost revenue reported in the portal submissions that could have been utilized to support the retention of the PRF funds, the Corporation still would have qualified to recognize all PRF payments received in Period 2 and Period 3. Cause and Effect - The review process surrounding the expenses reported was not sufficient to ensure that the expenses were accurately reported. As a result, the report submitted was inaccurate, but the schedule of expenditure of federal awards was not impacted. Recommendation - We recommend the Corporation enhance controls, including additional levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Corporation accepts the finding and will implement additional layers of review regarding expense submission to ensure the reports are submitted within the established guidelines. As stated above, the lost revenue from the COVID-19 pandemic more than offsets this finding, and there are no resulting PRF recognition issues.

ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19: Provider Relief Fund and American Rescue Plan Rural Distribution (PRF) Federal Award Identification Number and Year - N/A, 2022 Pass-through Entity N/A, Direct funded Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund Distributions and American Rescue Plan Rural Distributions Post Payment Notice of Reporting Requirements dated October 27, 2022, published by the U.S. Department of Health and Human Services (HHS), allowable expenses paid with general and targeted PRF distributions may be reported as a use of PRF funds, provided that the expenses have not been reimbursed by another source. Additionally, per the Health Resources and Services Administration (HRSA) PRF Reporting Portal user guide, "the reporting entity must report the use of these payments by indicating the quarterly expenses reimbursed for these payments" once these expenses have been entered, and the portal will automatically calculate an unreimbursed expense amount for any PRF expenses entered that exceed PRF funding received. As a result of this calculation, the directions from HRSA require users to only input expenses related to the current period's payments in the current portal submission. Condition - The Corporation's controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of expenses. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information Context - The reporting submission for health care expenses did not follow the guidelines published by HHS. The Corporation's Period 2 and Period 3 portal submissions overstated expenses by $3,032,735 and $6,185,506, respectively, that were included within previously submitted portal submission. These expenses should not have been re entered in the Period 2 and Period 3 submissions. Due to the Corporation having excess allowable health care expenses and lost revenue reported in the portal submissions that could have been utilized to support the retention of the PRF funds, the Corporation still would have qualified to recognize all PRF payments received in Period 2 and Period 3. Cause and Effect - The review process surrounding the expenses reported was not sufficient to ensure that the expenses were accurately reported. As a result, the report submitted was inaccurate, but the schedule of expenditure of federal awards was not impacted. Recommendation - We recommend the Corporation enhance controls, including additional levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Corporation accepts the finding and will implement additional layers of review regarding expense submission to ensure the reports are submitted within the established guidelines. As stated above, the lost revenue from the COVID-19 pandemic more than offsets this finding, and there are no resulting PRF recognition issues.