Audit 29143

FY End
2022-03-31
Total Expended
$5.52M
Findings
4
Programs
2
Organization: Holland Hospital (MI)
Year: 2022 Accepted: 2022-12-21

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
33120 2022-001 Significant Deficiency - L
33121 2022-002 Significant Deficiency - A
609562 2022-001 Significant Deficiency - L
609563 2022-002 Significant Deficiency - A

Programs

ALN Program Spent Major Findings
93.498 Covid-19 - Provider Relief Fund $5.27M Yes 2
93.461 Covid-19 - Testing for the Uninsured $252,668 - 0

Contacts

Name Title Type
NMRQLLDT3FJ5 Alex Roehling Auditee
6163943456 Adam Stevenson Auditor
No contacts on file

Notes to SEFA

Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Holland Hospital (the Hospital) under programs of the federal government for the year ended March 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 Hospital, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the Hospital. Expenditures reported in the Schedule are reported on the accrual basis 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 (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 the amounts on the Schedule be reported corresponding to reporting requirements of the HHS PRF Portal. Payments from HHS for PRF are assigned a payment received period (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 Portal after each period's deadline to use the funds (i.e., after the end of the period of availability). The Hospital has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID 19 Provider Relief Fund Federal Award Identification Number and Year - N/A - 2022 Pass-through Entity - N/A - direct funded Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, recipients may choose to apply PRF payments towards lost revenues using one of three options, up to the amount: Option i: of the difference between actual patient care revenues; Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues; or Option iii: calculated by any reasonable methodology of estimating revenues. Condition - The Hospital's controls in place for reporting submissions did not identify that Post Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 1 reporting submission for lost revenue did not follow the acceptable options provided by the HHS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Refer to context below for additional information. Context - The Hospital was required to submit one portal submision, which contained lost revenue amounts for six total quarters (four for calendar year 2020 and two for calendar year 2021). The Period 1 reporting submission for lost revenue did not follow the acceptable options provided by the HHS, as noted in the criteria, above. The Hospital had reported to HHS that they used option ii to calculate their their lost revenue included in their portal submissions. However, the budgeted amounts for patient care revenue relating to the second quarter in calendar year 2021 were not approved prior to March 27, 2020, therefore, option ii was not allowable. The Hospital should have selected option iii in its portal submissions. Finally, by not selecting option iii in the portal submission, the Hospital omitted required information related to the reason for selecting option iii in their submissions. Cause and Effect - Appropriate review of the reporting submissions was not completed to ensure the reports followed required guidelines. As a result, the Hospital selected an incorrect methodology option (option ii) for reporting lost revenues. Additionally, because the Hospital used an incorrect option, they did not provide additional information to HHS required under the correct option (option iii). The additional information included an explanation for the reason the Hospital used option iii for reporting lost revenue. Recommendation - We recommend that the Hospital implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Hospital will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue methodology is used in future reporting periods. The third submission to HRSA (9/30/2022) corrected this oversight and used the eligible budget values for all previous submissions (i.e., this first one) and future submissions.
ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID 19 Provider Relief Fund Federal Award Identification Number and Year - N/A - 2022 Pass through Entity - N/A - direct funded Finding Type - Significant deficiency Repeat Finding - No Criteria - Per the compliance supplement Provider Relief Funding may not be used to reimburse expenses or losses that have been reimbursed to other sources or for which other sources are obligated to reimburse. Expenses submitted must also be tied to the organization's costs incurred to fight the COVID 19 pandemic. Condition - As part of the Period 1 portal submission, the Hospital included $5,268,942 of eligible expenses. Within it's listing of eligible expenses for reimbursement, the Hospital submitted a purchase order for $4,810 which included items that were also submitted to reimbursement from other sources and items that were ineligible for reimbursement under the grant, as the expense was not tied to COVID 19. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Refer to context below for additional information. Context - The Hospital's controls in place for reporting submissions did not identify that compliance supplement guidelines were not followed related to review of the portal submission. The Period 1 reporting submission and supporting inputs were not appropriately reviewed by a second individual who did not prepare the inputs. Cause and Effect - Appropriate review of the reporting submissions was not completed. As a result, the Hospital had errors in the reporting submissions due to the insufficient review process. Recommendation - We recommend that the Hospital implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Planned Corrective Actions - The Hospital will review its processes surrounding the methodologies used to complete portal submissions and will implement additional levels of review to ensure that the proper reporting is followed in future portal periods.
ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID 19 Provider Relief Fund Federal Award Identification Number and Year - N/A - 2022 Pass-through Entity - N/A - direct funded Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, recipients may choose to apply PRF payments towards lost revenues using one of three options, up to the amount: Option i: of the difference between actual patient care revenues; Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues; or Option iii: calculated by any reasonable methodology of estimating revenues. Condition - The Hospital's controls in place for reporting submissions did not identify that Post Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 1 reporting submission for lost revenue did not follow the acceptable options provided by the HHS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Refer to context below for additional information. Context - The Hospital was required to submit one portal submision, which contained lost revenue amounts for six total quarters (four for calendar year 2020 and two for calendar year 2021). The Period 1 reporting submission for lost revenue did not follow the acceptable options provided by the HHS, as noted in the criteria, above. The Hospital had reported to HHS that they used option ii to calculate their their lost revenue included in their portal submissions. However, the budgeted amounts for patient care revenue relating to the second quarter in calendar year 2021 were not approved prior to March 27, 2020, therefore, option ii was not allowable. The Hospital should have selected option iii in its portal submissions. Finally, by not selecting option iii in the portal submission, the Hospital omitted required information related to the reason for selecting option iii in their submissions. Cause and Effect - Appropriate review of the reporting submissions was not completed to ensure the reports followed required guidelines. As a result, the Hospital selected an incorrect methodology option (option ii) for reporting lost revenues. Additionally, because the Hospital used an incorrect option, they did not provide additional information to HHS required under the correct option (option iii). The additional information included an explanation for the reason the Hospital used option iii for reporting lost revenue. Recommendation - We recommend that the Hospital implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Hospital will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue methodology is used in future reporting periods. The third submission to HRSA (9/30/2022) corrected this oversight and used the eligible budget values for all previous submissions (i.e., this first one) and future submissions.
ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID 19 Provider Relief Fund Federal Award Identification Number and Year - N/A - 2022 Pass through Entity - N/A - direct funded Finding Type - Significant deficiency Repeat Finding - No Criteria - Per the compliance supplement Provider Relief Funding may not be used to reimburse expenses or losses that have been reimbursed to other sources or for which other sources are obligated to reimburse. Expenses submitted must also be tied to the organization's costs incurred to fight the COVID 19 pandemic. Condition - As part of the Period 1 portal submission, the Hospital included $5,268,942 of eligible expenses. Within it's listing of eligible expenses for reimbursement, the Hospital submitted a purchase order for $4,810 which included items that were also submitted to reimbursement from other sources and items that were ineligible for reimbursement under the grant, as the expense was not tied to COVID 19. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Refer to context below for additional information. Context - The Hospital's controls in place for reporting submissions did not identify that compliance supplement guidelines were not followed related to review of the portal submission. The Period 1 reporting submission and supporting inputs were not appropriately reviewed by a second individual who did not prepare the inputs. Cause and Effect - Appropriate review of the reporting submissions was not completed. As a result, the Hospital had errors in the reporting submissions due to the insufficient review process. Recommendation - We recommend that the Hospital implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Planned Corrective Actions - The Hospital will review its processes surrounding the methodologies used to complete portal submissions and will implement additional levels of review to ensure that the proper reporting is followed in future portal periods.