FAC Explorer

Audit 25693

FY End
2022-12-31
Total Expended
$66.15M
Findings
2
Programs
26
Organization: Promedica Health System and Subsidiaries (OH)
Year: 2022 Accepted: 2023-09-28
Auditor: Plante & Moran PLLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
30771 2022-003 Material Weakness - L
607213 2022-003 Material Weakness - L

Programs

ALN Program Spent Major Findings
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan Rural Distribution $53.65M Yes 1
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $3.95M Yes 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $950,000 Yes 0
93.155 Rural Health Research Centers $257,853 - 0
10.569 Emergency Food Assistance Program (food Commodities) $242,000 - 0
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $230,788 - 0
10.551 Supplemental Nutrition Assistance Program $223,671 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $175,000 - 0
93.884 Grants for Primary Care Training and Enhancement $169,391 - 0
93.461 Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $144,231 - 0
93.926 Healthy Start Initiative $108,121 - 0
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $85,751 - 0
93.889 National Bioterrorism Hospital Preparedness Program $76,994 - 0
93.394 Cancer Detection and Diagnosis Research $69,690 - 0
20.616 National Priority Safety Programs $69,000 - 0
93.136 Injury Prevention and Control Research and State and Community Based Programs $63,931 - 0
93.395 Cancer Treatment Research $57,906 - 0
93.558 Temporary Assistance for Needy Families $56,000 - 0
93.788 Opioid Str $52,882 - 0
93.301 Small Rural Hospital Improvement Grant Program $47,244 - 0
93.991 Preventive Health and Health Services Block Grant $11,919 - 0
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $10,659 - 0
16.575 Crime Victim Assistance $5,336 - 0
93.110 Maternal and Child Health Federal Consolidated Programs $3,464 - 0
93.839 Blood Diseases and Resources Research $1,771 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $852 - 0

Contacts

Name Title Type
J3QACS9PPD99 Kyle Kickbusch Auditee
4192525965 Oliver Jurkovic Auditor
No contacts on file

Notes to SEFA

Title: Noncash Assistance Accounting Policies: The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of ProMedica Health System and Subsidiaries (the "System") under programs of the federal government for the year ended December 31, 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 the System, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the System. Expenditures reported in the Schedule are reported on an accrual basis of accounting with the exception of expenditures passed through the Ohio Department of Health (ODH). The ODH expenditures are reported on a cash basis in accordance with guidance provided by ODH. 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 (PRF) and American Rescue Plan (ARP) Rural Distribution (PRF program). The PRF program 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 the amounts on the Schedule should be reported corresponding to reporting requirement of the HHS PRF Reporting Portal. Payments from HHS for the PRF program are assigned to payment received periods (each, a "period") based upon the date each PRF payment was received. Each period has a specified period of availability and timing of reporting requirements. Entities report into the HHS PRF Reporting Portal after each period's deadline to use the funds (i.e., after the end of the period of availability). The pass through entity identifying numbers are presented where available. The System has elected to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: Y Rate Explanation: The auditee used 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 the following noncash assistance during the year ended December 31, 2022 that is included in the schedule of expenditures of federal awards: See Notes to the SEFA for table.

Finding Details

Finding 2022-003
Assistance Listing, 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 Distribution Post Payment Notice of Reporting Requirements dated October 27, 2022, infection control expenses paid with Nursing Home Infection Control distributions, allowable expenses may be reported as a use of targeted funds. Allowable expenses must be those that are unreimbursed by other sources and determined using the recipient's basis of accounting. Condition - ProMedica Health System's controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of infection control expenses in the correct period. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information. Context - The reporting submissions for certain HCR entities did not follow the guidelines published by the U.S. Department of Health and Human Services (HHS). These entities did not break out infection control expenses in the correct quarter in which they were expended. All infection control expenses were entered in quarter 1 and quarter 2 2022, regardless of if they were incurred in 2020 or 2021. Cause and Effect - Appropriate review of the expenses was not completed to ensure that eligible expenses were entered into correct period. As a result, the reports submitted were inaccurate, but the schedule of expenditure was not impacted. Recommendation - We recommend ProMedica Health System implement controls, including 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 - Management fully understands and acknowledges the importance of identifying and complying with the reporting guidelines of federal awards, including the reporting of infection control expenses in the correct period. The receipt of Provider Relief Funds has broadened the scope of individuals that are responsible for reporting of Federal awards to those outside of the Grants and Research departments. Expenses for the Provider Relief Funds were correctly captured by period incurred and appropriately tracked for allowability. ProMedica has implemented a review procedure of the Provider Relief Funds consistent with other grant reporting so that the HRSA reports will be reviewed by a Grants Advisor or Grants Analyst prior to submission to ensure that eligible expenses are entered into the correct period in accordance with the guidelines established by HHS.
Finding 2022-003
Assistance Listing, 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 Distribution Post Payment Notice of Reporting Requirements dated October 27, 2022, infection control expenses paid with Nursing Home Infection Control distributions, allowable expenses may be reported as a use of targeted funds. Allowable expenses must be those that are unreimbursed by other sources and determined using the recipient's basis of accounting. Condition - ProMedica Health System's controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of infection control expenses in the correct period. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information. Context - The reporting submissions for certain HCR entities did not follow the guidelines published by the U.S. Department of Health and Human Services (HHS). These entities did not break out infection control expenses in the correct quarter in which they were expended. All infection control expenses were entered in quarter 1 and quarter 2 2022, regardless of if they were incurred in 2020 or 2021. Cause and Effect - Appropriate review of the expenses was not completed to ensure that eligible expenses were entered into correct period. As a result, the reports submitted were inaccurate, but the schedule of expenditure was not impacted. Recommendation - We recommend ProMedica Health System implement controls, including 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 - Management fully understands and acknowledges the importance of identifying and complying with the reporting guidelines of federal awards, including the reporting of infection control expenses in the correct period. The receipt of Provider Relief Funds has broadened the scope of individuals that are responsible for reporting of Federal awards to those outside of the Grants and Research departments. Expenses for the Provider Relief Funds were correctly captured by period incurred and appropriately tracked for allowability. ProMedica has implemented a review procedure of the Provider Relief Funds consistent with other grant reporting so that the HRSA reports will be reviewed by a Grants Advisor or Grants Analyst prior to submission to ensure that eligible expenses are entered into the correct period in accordance with the guidelines established by HHS.