Audit 29363

2022-002 Establishment of Internal Controls over Calculations and Data Submitted Through HRSA Portal for PRF Funds DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) Reporting Provider Relief Fund ? Federal Assistance Listing Number 93.498 Criteria: The terms and conditions of the Provider Relief Fund (PRF) award require that recipients be able to demonstrate that lost revenues or expenses attributable to coronavirus, excluding expenses and losses that have been reimbursed from other sources or that other sources are obligated to reimburse, meet, or exceed total payments from Provider Relief Fund. Specific reporting requirements exist based on the timing of the receipt of the funds. Data entered into the reporting portal administered by the Health Resources and Services Administration (HRSA) must be done within the timeline established by regulation. Questioned Costs: $310,568 Condition: The District reported certain Provider Relief Fund expenses of $310,568 as an expense in both Period 1 and Period 2; therefore, the data input into the reporting portal was not accurate. Repeat Finding: No. Cause: The District did not establish internal controls to review and approve the expenses reported. Effect: Failure by a provider to comply with any of the terms and conditions of the award can result in action by HHS to recover some or all of the payment. Recommendation: The District should immediately establish the proper internal controls to ensure the data input into the reporting portal is accurate. The District should also contact HHS regarding possible repayment of funds. View of Responsible Official: The District will establish proper internal controls to ensure the data input into the reporting portal is accurate and eligible expenses are tracked appropriately. The District will contact HHS regarding possible repayment of funds.

2022-003 Enhancement of Policies and Procedures for Federal Awards Criteria: The Uniform Guidance administrative requirements and cost principles apply to federal funding awarded on or after December 25, 2014, 2 CFR 200, Subpart D ? Post Federal Award Requirements and Subpart E ? Cost Principles of the Uniform Guidance require specific written policies relative to federal awards. Questioned Costs: None. Condition: During our audit procedures we identified that the written policies and procedures of the District do not directly address all required compliance areas with the Uniform Guidance for federal programs. Additionally, documentation could be improved to track and identify time spent directly on COVID-19 initiatives. Repeat Finding: No. Cause: The District has not developed the policies and procedures required by the Uniform Guidance. Effect: The District is susceptible to an increase risk of noncompliance with federal awarding requirements as they relate to allowable costs. Recommendation: The written policies and procedures of the District should be enhanced to ensure compliance with the Uniform Guidance as it relates to allowable costs. The District should implement a way of tracking the time and effort spent by employees on COVID-19 initiatives. View of Responsible Official: The District will create policies and procedures specific to the compliance requirements as stated by the Uniform Guidance. Additionally, the District will meet to determine the most effective way to document time and effort on COVID-19 initiatives.

2022-002 Establishment of Internal Controls over Calculations and Data Submitted Through HRSA Portal for PRF Funds DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) Reporting Provider Relief Fund ? Federal Assistance Listing Number 93.498 Criteria: The terms and conditions of the Provider Relief Fund (PRF) award require that recipients be able to demonstrate that lost revenues or expenses attributable to coronavirus, excluding expenses and losses that have been reimbursed from other sources or that other sources are obligated to reimburse, meet, or exceed total payments from Provider Relief Fund. Specific reporting requirements exist based on the timing of the receipt of the funds. Data entered into the reporting portal administered by the Health Resources and Services Administration (HRSA) must be done within the timeline established by regulation. Questioned Costs: $310,568 Condition: The District reported certain Provider Relief Fund expenses of $310,568 as an expense in both Period 1 and Period 2; therefore, the data input into the reporting portal was not accurate. Repeat Finding: No. Cause: The District did not establish internal controls to review and approve the expenses reported. Effect: Failure by a provider to comply with any of the terms and conditions of the award can result in action by HHS to recover some or all of the payment. Recommendation: The District should immediately establish the proper internal controls to ensure the data input into the reporting portal is accurate. The District should also contact HHS regarding possible repayment of funds. View of Responsible Official: The District will establish proper internal controls to ensure the data input into the reporting portal is accurate and eligible expenses are tracked appropriately. The District will contact HHS regarding possible repayment of funds.

2022-003 Enhancement of Policies and Procedures for Federal Awards Criteria: The Uniform Guidance administrative requirements and cost principles apply to federal funding awarded on or after December 25, 2014, 2 CFR 200, Subpart D ? Post Federal Award Requirements and Subpart E ? Cost Principles of the Uniform Guidance require specific written policies relative to federal awards. Questioned Costs: None. Condition: During our audit procedures we identified that the written policies and procedures of the District do not directly address all required compliance areas with the Uniform Guidance for federal programs. Additionally, documentation could be improved to track and identify time spent directly on COVID-19 initiatives. Repeat Finding: No. Cause: The District has not developed the policies and procedures required by the Uniform Guidance. Effect: The District is susceptible to an increase risk of noncompliance with federal awarding requirements as they relate to allowable costs. Recommendation: The written policies and procedures of the District should be enhanced to ensure compliance with the Uniform Guidance as it relates to allowable costs. The District should implement a way of tracking the time and effort spent by employees on COVID-19 initiatives. View of Responsible Official: The District will create policies and procedures specific to the compliance requirements as stated by the Uniform Guidance. Additionally, the District will meet to determine the most effective way to document time and effort on COVID-19 initiatives.