Audit 26499

Provider Relief Fund and American Rescue Plan Act (ARP) Rural Distribution Federal Assistance Listing No. 93.498 U.S. Department of Health and Human Services Criteria or Specific Requirement ? Reporting (45 CFR 75.342) and Activities Allowed/Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116?136, 134 Stat. 563 and Pub. L. No. 116?139, 134 Stat. 622 and 623) Condition ? The Organization is required to prepare and submit phase one Provider Relief Funding Reporting. This report is to be prepared using accurate financial information and submitted by the deadline established. Questioned Costs ? Unknown Context ? The period one Provider Relief Fund Program and American Rescue Plan (ARP) Rural Distribution (collectively the ?Provider Relief Fund?) report was tested. The Organization selected option three to report lost revenues, using a calculation that excluded certain patient service revenue categories but did not disclose the categories in sufficient detail in the required narrative that would allow the Health Resources Services Administration (HRSA) to be able to clearly understand the categories that have been excluded from the option three calculation. Effect ? The report provided to HRSA included adjustments that were not adequately described and disclosed through the Provider Relief Fund phase one report. Cause ? The narrative did not fully and clearly describe the exclusions from patient service revenue in the narrative of the method for calculating lost revenue, as required by the Provider Relief Fund terms and conditions. Identification As a Repeat Finding ? Not a repeat finding. Recommendation ? Policies and procedures over federal grant reporting should be modified to ensure reports and supporting documentation provided to regulatory agencies are clear, accurate, and easily understood. Views of Responsible Officials and Planned Corrective Actions ? Advance Community Health was inundated with HRSA reporting due to the multiple funding we received in response to the Covid-19 Pandemic. In an effort to help health centers deal expeditiously with the Covid crisis some of the funding was given in advance with reporting requirements to follow. The rush to get funding out to address the Covid-19 pandemic crisis resulted in reporting requirements that were developed and implemented very quickly, and the reporting requirements were confusing to many health centers. The Provider Relief Funding was one of the instances in which funding was given in advance with reporting requirements to follow. As a result of the confusion surrounding these last-minute reporting requirements, we believe that the former CFO inadvertently omitted certain revenue that perhaps should have been included in the Provider Relief Funding (PRF) report and there was no clear explanation in the narrative section as to why these revenues were omitted. We attempted to recall and amend the PRF report but were told by the PRF reporting team that we are unable to amend the report at this time. However, should the opportunity to amend the PRF Report occur, we will make the appropriate amendment to the PRF report with a reconciliation and narrative that will support the earning of the PRF funding. To prevent future occurrences of where it is not clear why revenue items are being omitted or included on a federal provider relief report, a reconciliation will be prepared that ties the revenue section of the PRF report with the revenue section of the internal financial statements. The reconciliation will clearly outline what is included in and what is omitted from the report and establish clear documentation to strongly support the amounts on the PRF report. A narrative documenting why certain revenue is omitted should be attached, which will clearly and concisely explain how the revenue amounts on the PRF report were derived. The reconciliation will be prepared by our senior accountant and reviewed by the CFO. Tiffany Robertson, the interim CFO and Rhonda Payne, our Chief Compliance Officer will be responsible for and will continue to assess our internal reporting processes. We will continue to conduct staff training as deemed necessary to ensure compliance with federal reporting requirements for PRF funding. The training and procedure should be implemented by December 2022.

Provider Relief Fund and American Rescue Plan Act (ARP) Rural Distribution Federal Assistance Listing No. 93.498 U.S. Department of Health and Human Services Criteria or Specific Requirement ? Reporting (45 CFR 75.342) and Activities Allowed/Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116?136, 134 Stat. 563 and Pub. L. No. 116?139, 134 Stat. 622 and 623) Condition ? The Organization is required to prepare and submit phase one Provider Relief Funding Reporting. This report is to be prepared using accurate financial information and submitted by the deadline established. Questioned Costs ? Unknown Context ? The period one Provider Relief Fund Program and American Rescue Plan (ARP) Rural Distribution (collectively the ?Provider Relief Fund?) report was tested. The Organization selected option three to report lost revenues, using a calculation that excluded certain patient service revenue categories but did not disclose the categories in sufficient detail in the required narrative that would allow the Health Resources Services Administration (HRSA) to be able to clearly understand the categories that have been excluded from the option three calculation. Effect ? The report provided to HRSA included adjustments that were not adequately described and disclosed through the Provider Relief Fund phase one report. Cause ? The narrative did not fully and clearly describe the exclusions from patient service revenue in the narrative of the method for calculating lost revenue, as required by the Provider Relief Fund terms and conditions. Identification As a Repeat Finding ? Not a repeat finding. Recommendation ? Policies and procedures over federal grant reporting should be modified to ensure reports and supporting documentation provided to regulatory agencies are clear, accurate, and easily understood. Views of Responsible Officials and Planned Corrective Actions ? Advance Community Health was inundated with HRSA reporting due to the multiple funding we received in response to the Covid-19 Pandemic. In an effort to help health centers deal expeditiously with the Covid crisis some of the funding was given in advance with reporting requirements to follow. The rush to get funding out to address the Covid-19 pandemic crisis resulted in reporting requirements that were developed and implemented very quickly, and the reporting requirements were confusing to many health centers. The Provider Relief Funding was one of the instances in which funding was given in advance with reporting requirements to follow. As a result of the confusion surrounding these last-minute reporting requirements, we believe that the former CFO inadvertently omitted certain revenue that perhaps should have been included in the Provider Relief Funding (PRF) report and there was no clear explanation in the narrative section as to why these revenues were omitted. We attempted to recall and amend the PRF report but were told by the PRF reporting team that we are unable to amend the report at this time. However, should the opportunity to amend the PRF Report occur, we will make the appropriate amendment to the PRF report with a reconciliation and narrative that will support the earning of the PRF funding. To prevent future occurrences of where it is not clear why revenue items are being omitted or included on a federal provider relief report, a reconciliation will be prepared that ties the revenue section of the PRF report with the revenue section of the internal financial statements. The reconciliation will clearly outline what is included in and what is omitted from the report and establish clear documentation to strongly support the amounts on the PRF report. A narrative documenting why certain revenue is omitted should be attached, which will clearly and concisely explain how the revenue amounts on the PRF report were derived. The reconciliation will be prepared by our senior accountant and reviewed by the CFO. Tiffany Robertson, the interim CFO and Rhonda Payne, our Chief Compliance Officer will be responsible for and will continue to assess our internal reporting processes. We will continue to conduct staff training as deemed necessary to ensure compliance with federal reporting requirements for PRF funding. The training and procedure should be implemented by December 2022.