Audit 295994

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CRF Subpart E section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; and (g) be adequately documented.”In addition, per the State of Illinois, Department of Healthcare and Family Services and Presence Senior Services Agreement No. ARPA230050, Nazarethville Retirement Home Agreement No. ARPA230159, and Presence Life Connections Agreement No. ARPA230263, Exhibit A requires the awards pursuant to this program to comply with the following criteria: “1. 65% of the funds awarded under this grant shall comply with the following criteria. a) Shall be expended only for premium pay for eligible workers; in addition to any wages or remuneration the eligible worker has already received; and shall be subject to the other requirements and limitations set forth in the American Rescue Plan Act of 2021 and related federal guidance. b) Upon receipt of funds, recipients shall distribute funds such that eligible workers receive an amount up to $13 per hour, but no more than $25,000 for the duration of the program. Recipients shall provide a written certification to the Department acknowledging compliance with this paragraph. d) Each recipient under this paragraph shall submit appropriate documentation acknowledging compliance with State and federal law. For purposes of this section, “eligible worker” means a permanent staff member, regardless of union affiliation, of a facility licensed by the Department of Public Health under the Nursing Home Care Act as a skilled nursing facility or intermediate care facility engaged in “essential work”, as defined by Section 9901 of the American Rescue Plan Act of 2021 and related federal guidance, as well as whose total pay is below 150% of the average annual wage for all occupations in the worker’s county of residence, as defined by the Bureau of Labor Statistics Occupational Employment and Wage Statistics; or is not exempt from the federal Fair Labor Standards Act overtime provisions.” Condition: Illinois – Internal controls over the review and approval of program expenditures for allowability and period of performance under the federal program were not in place for Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) administering the federal program.Illinois – Nazarethville Retirement Home (Agreement No. ARPA230159) did not meet the criteria per Exhibit A, paragraph 1.a. In addition, Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) did not comply with the criteria per Exhibit A, paragraphs 1.b and 1.d. St. Agnes Healthcare, Inc., Maryland – Timecards for employees that were submitted for substantiation of funding for the federal program were not consistently reviewed and approved. Cause: Ascension Living, Illinois: •Ascension Living did not have effective internal controls in place over the review and approval of expenses and period of performance for certain locations administering the grant. •Ascension Living did not have internal controls in place to review and approve the requirements in Exhibit A and the analysis performed over the requirements included in Exhibit A of the program grant agreements. St. Agnes Healthcare, Inc., Maryland – Timecards were processed without manager approval. Effect or potential effect: Expenses may be charged to the federal award that are not in compliance with the federal or pass-through grant agreement. The System was not in noncompliance with the terms and conditions of the federal program. Questioned costs: $59,425 – Assistance Listing No. 21.027, Pass-Through Award Number ARPA230050 Context: Ascension Living, Illinois: • At one location, per Exhibit A, paragraph 1.a., only 62% of the funds were spent for premium pay versus the required 65%, resulting in a shortage of premium pay of $57,700. • At one location, per Exhibit A, paragraph 1.b., one employee’s salary exceeded the limit of $25,000 allowable to be funded by the award by $1,725. Total expenses subject to the requirements of Exhibit A of the grant agreement were $2,105,470, representing 44% of total federal expenditures of $4,798,357. For Assistance Listing No. 21.027, total expenses for Ascension Living, Illinois, were $3,474,484, representing 72% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. St. Agnes Healthcare, Inc., Maryland – For two (totaling $4,526) of ten (totaling $21,950) (11%) payroll transactions sampled during the fiscal year, the employee’s timecards did not have evidence of review and approval by the employee’s manager for two months. For Assistance Listing No. 21.027, total payroll costs for the Maryland location were $113,188, representing 2% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living, Illinois – Ascension Living should implement internal controls to review the limitations requirement included in Exhibit A of the grant agreement and that the requirements are met prior to drawing down funds, required communication with the grantor is submitted, and required analysis is performed to be in compliance with the terms and conditions of the grant agreements. St. Agnes Healthcare, Inc., Maryland – The System should reinforce the importance of adhering to its internal controls over the review and approval of timecards. Views of responsible officials: Ascension Living management acknowledges that internal controls were not working effectively regarding review of the calculated limitations and allocations. Management has reserved the questioned costs and has communicated with the State on their desired method of repayment. For future grants, Ascension Living will implement controls for appropriate review and approval and to have a secondary review to validate calculations. St. Agnes Healthcare, Inc., Maryland - This finding pertains to retroactive grants where expenses were incurred in previous periods but were subsequently eligible for grant reimbursement. Management is working on creating a report to identify timecards lacking manager approval for exclusion as allowable grant expenses. Grant Accounting is incorporating a Time and Effort tracking feature, a separate approval control to mitigate the issue of timecards lacking manager approval.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The terms and conditions of the pass-through agreements with the states required the submission of the following special reports during the fiscal year. See table/chart in the finding Condition: The Quarterly Reimbursement Certifications and Quarterly Metrics Reports required by the state of Illinois were not submitted timely for various quarters during fiscal year 2023. The Quarterly Progress and Performance Metrics Report required by the state of Maryland was filed with incomplete information. Cause:Internal controls were not effective to ensure submission of the reports in accordance with the due dates under the pass-through agreement with the State of Illinois. In addition, internal controls were not effective to ensure all required data is reported on the reports required by the state of Maryland. Effect or potential effect: The System and Ascension Living did not file reports with the state of Illinois on a timely basis and was not in compliance with the terms and conditions of the federal program reporting requirements for the state of Maryland. Questioned costs: None. Context: 15 reports out of 21 required report submissions for the Illinois market were not submitted or submitted late. 1 report required for submission for the Maryland market did not include a required key year-to-date data field required by the state of Maryland. St. Agnes Healthcare, Inc., Maryland and Ascension Living, Illinois federal expenditures totaled $164,195 and $4,474,484, respectively, representing 3% and 93%, respectively, of total federal expenditures for Assistance Listing No. 21.027 of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The System should implement an internal control over the monitoring of due dates of all reports required to be submitted under the federal program to ensure they are submitted timely. The System should ensure internal controls over the review of required reports are enhanced to include review of key data. Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, the System will reinforce the importance to operations of oversight and accountability to submit required reports.

Information of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CRF Subpart E section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; and (g) be adequately documented.”In addition, per the State of Illinois, Department of Healthcare and Family Services and Presence Senior Services Agreement No. ARPA230050, Nazarethville Retirement Home Agreement No. ARPA230159, and Presence Life Connections Agreement No. ARPA230263, Exhibit A requires the awards pursuant to this program to comply with the following criteria: “1. 65% of the funds awarded under this grant shall comply with the following criteria. a) Shall be expended only for premium pay for eligible workers; in addition to any wages or remuneration the eligible worker has already received; and shall be subject to the other requirements and limitations set forth in the American Rescue Plan Act of 2021 and related federal guidance. b) Upon receipt of funds, recipients shall distribute funds such that eligible workers receive an amount up to $13 per hour, but no more than $25,000 for the duration of the program. Recipients shall provide a written certification to the Department acknowledging compliance with this paragraph. d) Each recipient under this paragraph shall submit appropriate documentation acknowledging compliance with State and federal law. For purposes of this section, “eligible worker” means a permanent staff member, regardless of union affiliation, of a facility licensed by the Department of Public Health under the Nursing Home Care Act as a skilled nursing facility or intermediate care facility engaged in “essential work”, as defined by Section 9901 of the American Rescue Plan Act of 2021 and related federal guidance, as well as whose total pay is below 150% of the average annual wage for all occupations in the worker’s county of residence, as defined by the Bureau of Labor Statistics Occupational Employment and Wage Statistics; or is not exempt from the federal Fair Labor Standards Act overtime provisions.” Condition: Illinois – Internal controls over the review and approval of program expenditures for allowability and period of performance under the federal program were not in place for Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) administering the federal program.Illinois – Nazarethville Retirement Home (Agreement No. ARPA230159) did not meet the criteria per Exhibit A, paragraph 1.a. In addition, Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) did not comply with the criteria per Exhibit A, paragraphs 1.b and 1.d. St. Agnes Healthcare, Inc., Maryland – Timecards for employees that were submitted for substantiation of funding for the federal program were not consistently reviewed and approved. Cause: Ascension Living, Illinois: •Ascension Living did not have effective internal controls in place over the review and approval of expenses and period of performance for certain locations administering the grant. •Ascension Living did not have internal controls in place to review and approve the requirements in Exhibit A and the analysis performed over the requirements included in Exhibit A of the program grant agreements. St. Agnes Healthcare, Inc., Maryland – Timecards were processed without manager approval. Effect or potential effect: Expenses may be charged to the federal award that are not in compliance with the federal or pass-through grant agreement. The System was not in noncompliance with the terms and conditions of the federal program. Questioned costs: $59,425 – Assistance Listing No. 21.027, Pass-Through Award Number ARPA230050 Context: Ascension Living, Illinois: • At one location, per Exhibit A, paragraph 1.a., only 62% of the funds were spent for premium pay versus the required 65%, resulting in a shortage of premium pay of $57,700. • At one location, per Exhibit A, paragraph 1.b., one employee’s salary exceeded the limit of $25,000 allowable to be funded by the award by $1,725. Total expenses subject to the requirements of Exhibit A of the grant agreement were $2,105,470, representing 44% of total federal expenditures of $4,798,357. For Assistance Listing No. 21.027, total expenses for Ascension Living, Illinois, were $3,474,484, representing 72% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. St. Agnes Healthcare, Inc., Maryland – For two (totaling $4,526) of ten (totaling $21,950) (11%) payroll transactions sampled during the fiscal year, the employee’s timecards did not have evidence of review and approval by the employee’s manager for two months. For Assistance Listing No. 21.027, total payroll costs for the Maryland location were $113,188, representing 2% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living, Illinois – Ascension Living should implement internal controls to review the limitations requirement included in Exhibit A of the grant agreement and that the requirements are met prior to drawing down funds, required communication with the grantor is submitted, and required analysis is performed to be in compliance with the terms and conditions of the grant agreements. St. Agnes Healthcare, Inc., Maryland – The System should reinforce the importance of adhering to its internal controls over the review and approval of timecards. Views of responsible officials: Ascension Living management acknowledges that internal controls were not working effectively regarding review of the calculated limitations and allocations. Management has reserved the questioned costs and has communicated with the State on their desired method of repayment. For future grants, Ascension Living will implement controls for appropriate review and approval and to have a secondary review to validate calculations. St. Agnes Healthcare, Inc., Maryland - This finding pertains to retroactive grants where expenses were incurred in previous periods but were subsequently eligible for grant reimbursement. Management is working on creating a report to identify timecards lacking manager approval for exclusion as allowable grant expenses. Grant Accounting is incorporating a Time and Effort tracking feature, a separate approval control to mitigate the issue of timecards lacking manager approval.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Internal controls over suspension and debarment related to new vendor set up were not in place for Ascension Living. Specifically, documentation was not retained evidencing the review of new vendors for suspension and debarment prior to adding them into MatrixCare, Ascension Living’s current vendor management platform.The System has an internal control to review the accuracy of the vendor files transferred from the System’s vendor management system to ProviderTrust, the System’s third-party vendor engaged to perform its suspension and debarment review. The review of the completeness and accuracy of the data transferred to ProviderTrust was only performed for three of the twelve months during fiscal year 2023. The System has several IT applications that contain source vendor listings. Internal controls were not in place over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment (Ascension Living, Illinois). Cause: Management at Ascension Living did not have a requirement to retain the supporting documentation evidencing the review of new vendors for suspension and debarment. The System’s internal control over the review of the accuracy of the data transfer to ProviderTrust was not designed to review the completeness and accuracy of the data each time it is transferred to the third-party vendor. Internal controls were not in place at Ascension Living over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment. Effect or potential effect: New vendors may be used that are suspended or debarred. Suspension and debarment vendor files provided to the third-party vendor may not be accurate or complete. The data from MatrixCare transferred to the third-party vendor for suspension and debarment may not be complete and accurate. Federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For Assistance Listing No. 21.027, procurement expenditures subject to suspension and debarment review for Ascension Living, Illinois, totaled $1,369,015, which represents approximately 29% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Total federal portion of procurement expenditures subject to suspension and debarment review was $2,279,109, which represents approximately 47% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living should formalize the review and approval process of new vendors for suspension and debarment by authorized individuals that would include retention of evidence of the review, including documentation of the elements of the review process validated by the reviewer. The System should develop internal controls to ensure the integrity of data transfer to the third-party vendor is validated each time the data is transferred. Views of responsible officials: Ascension Living will provide education to their associates performing initial suspension and debarment screening as part of onboarding control activities to retain evidence of their review and the supporting documentation. Management will reassess controls over the data transfer application used to send the vendor data file to the third-party vendor, ProviderTrust. The System will explore implementing compensating controls for MatrixCare. The application is anticipated to be sunset in early 2025, when the process is migrated to Oracle Cloud and the established ProviderTrust processes.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The terms and conditions of the pass-through agreements with the states required the submission of the following special reports during the fiscal year. See table/chart in the finding Condition: The Quarterly Reimbursement Certifications and Quarterly Metrics Reports required by the state of Illinois were not submitted timely for various quarters during fiscal year 2023. The Quarterly Progress and Performance Metrics Report required by the state of Maryland was filed with incomplete information. Cause:Internal controls were not effective to ensure submission of the reports in accordance with the due dates under the pass-through agreement with the State of Illinois. In addition, internal controls were not effective to ensure all required data is reported on the reports required by the state of Maryland. Effect or potential effect: The System and Ascension Living did not file reports with the state of Illinois on a timely basis and was not in compliance with the terms and conditions of the federal program reporting requirements for the state of Maryland. Questioned costs: None. Context: 15 reports out of 21 required report submissions for the Illinois market were not submitted or submitted late. 1 report required for submission for the Maryland market did not include a required key year-to-date data field required by the state of Maryland. St. Agnes Healthcare, Inc., Maryland and Ascension Living, Illinois federal expenditures totaled $164,195 and $4,474,484, respectively, representing 3% and 93%, respectively, of total federal expenditures for Assistance Listing No. 21.027 of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The System should implement an internal control over the monitoring of due dates of all reports required to be submitted under the federal program to ensure they are submitted timely. The System should ensure internal controls over the review of required reports are enhanced to include review of key data. Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, the System will reinforce the importance to operations of oversight and accountability to submit required reports.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Internal controls over suspension and debarment related to new vendor set up were not in place for Ascension Living. Specifically, documentation was not retained evidencing the review of new vendors for suspension and debarment prior to adding them into MatrixCare, Ascension Living’s current vendor management platform.The System has an internal control to review the accuracy of the vendor files transferred from the System’s vendor management system to ProviderTrust, the System’s third-party vendor engaged to perform its suspension and debarment review. The review of the completeness and accuracy of the data transferred to ProviderTrust was only performed for three of the twelve months during fiscal year 2023. The System has several IT applications that contain source vendor listings. Internal controls were not in place over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment (Ascension Living, Illinois). Cause: Management at Ascension Living did not have a requirement to retain the supporting documentation evidencing the review of new vendors for suspension and debarment. The System’s internal control over the review of the accuracy of the data transfer to ProviderTrust was not designed to review the completeness and accuracy of the data each time it is transferred to the third-party vendor. Internal controls were not in place at Ascension Living over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment. Effect or potential effect: New vendors may be used that are suspended or debarred. Suspension and debarment vendor files provided to the third-party vendor may not be accurate or complete. The data from MatrixCare transferred to the third-party vendor for suspension and debarment may not be complete and accurate. Federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For Assistance Listing No. 21.027, procurement expenditures subject to suspension and debarment review for Ascension Living, Illinois, totaled $1,369,015, which represents approximately 29% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Total federal portion of procurement expenditures subject to suspension and debarment review was $2,279,109, which represents approximately 47% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living should formalize the review and approval process of new vendors for suspension and debarment by authorized individuals that would include retention of evidence of the review, including documentation of the elements of the review process validated by the reviewer. The System should develop internal controls to ensure the integrity of data transfer to the third-party vendor is validated each time the data is transferred. Views of responsible officials: Ascension Living will provide education to their associates performing initial suspension and debarment screening as part of onboarding control activities to retain evidence of their review and the supporting documentation. Management will reassess controls over the data transfer application used to send the vendor data file to the third-party vendor, ProviderTrust. The System will explore implementing compensating controls for MatrixCare. The application is anticipated to be sunset in early 2025, when the process is migrated to Oracle Cloud and the established ProviderTrust processes.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The terms and conditions of the pass-through agreements with the states required the submission of the following special reports during the fiscal year. See table/chart in the finding Condition: The Quarterly Reimbursement Certifications and Quarterly Metrics Reports required by the state of Illinois were not submitted timely for various quarters during fiscal year 2023. The Quarterly Progress and Performance Metrics Report required by the state of Maryland was filed with incomplete information. Cause:Internal controls were not effective to ensure submission of the reports in accordance with the due dates under the pass-through agreement with the State of Illinois. In addition, internal controls were not effective to ensure all required data is reported on the reports required by the state of Maryland. Effect or potential effect: The System and Ascension Living did not file reports with the state of Illinois on a timely basis and was not in compliance with the terms and conditions of the federal program reporting requirements for the state of Maryland. Questioned costs: None. Context: 15 reports out of 21 required report submissions for the Illinois market were not submitted or submitted late. 1 report required for submission for the Maryland market did not include a required key year-to-date data field required by the state of Maryland. St. Agnes Healthcare, Inc., Maryland and Ascension Living, Illinois federal expenditures totaled $164,195 and $4,474,484, respectively, representing 3% and 93%, respectively, of total federal expenditures for Assistance Listing No. 21.027 of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The System should implement an internal control over the monitoring of due dates of all reports required to be submitted under the federal program to ensure they are submitted timely. The System should ensure internal controls over the review of required reports are enhanced to include review of key data. Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, the System will reinforce the importance to operations of oversight and accountability to submit required reports.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CRF Subpart E section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; and (g) be adequately documented.”In addition, per the State of Illinois, Department of Healthcare and Family Services and Presence Senior Services Agreement No. ARPA230050, Nazarethville Retirement Home Agreement No. ARPA230159, and Presence Life Connections Agreement No. ARPA230263, Exhibit A requires the awards pursuant to this program to comply with the following criteria: “1. 65% of the funds awarded under this grant shall comply with the following criteria. a) Shall be expended only for premium pay for eligible workers; in addition to any wages or remuneration the eligible worker has already received; and shall be subject to the other requirements and limitations set forth in the American Rescue Plan Act of 2021 and related federal guidance. b) Upon receipt of funds, recipients shall distribute funds such that eligible workers receive an amount up to $13 per hour, but no more than $25,000 for the duration of the program. Recipients shall provide a written certification to the Department acknowledging compliance with this paragraph. d) Each recipient under this paragraph shall submit appropriate documentation acknowledging compliance with State and federal law. For purposes of this section, “eligible worker” means a permanent staff member, regardless of union affiliation, of a facility licensed by the Department of Public Health under the Nursing Home Care Act as a skilled nursing facility or intermediate care facility engaged in “essential work”, as defined by Section 9901 of the American Rescue Plan Act of 2021 and related federal guidance, as well as whose total pay is below 150% of the average annual wage for all occupations in the worker’s county of residence, as defined by the Bureau of Labor Statistics Occupational Employment and Wage Statistics; or is not exempt from the federal Fair Labor Standards Act overtime provisions.” Condition: Illinois – Internal controls over the review and approval of program expenditures for allowability and period of performance under the federal program were not in place for Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) administering the federal program.Illinois – Nazarethville Retirement Home (Agreement No. ARPA230159) did not meet the criteria per Exhibit A, paragraph 1.a. In addition, Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) did not comply with the criteria per Exhibit A, paragraphs 1.b and 1.d. St. Agnes Healthcare, Inc., Maryland – Timecards for employees that were submitted for substantiation of funding for the federal program were not consistently reviewed and approved. Cause: Ascension Living, Illinois: •Ascension Living did not have effective internal controls in place over the review and approval of expenses and period of performance for certain locations administering the grant. •Ascension Living did not have internal controls in place to review and approve the requirements in Exhibit A and the analysis performed over the requirements included in Exhibit A of the program grant agreements. St. Agnes Healthcare, Inc., Maryland – Timecards were processed without manager approval. Effect or potential effect: Expenses may be charged to the federal award that are not in compliance with the federal or pass-through grant agreement. The System was not in noncompliance with the terms and conditions of the federal program. Questioned costs: $59,425 – Assistance Listing No. 21.027, Pass-Through Award Number ARPA230050 Context: Ascension Living, Illinois: • At one location, per Exhibit A, paragraph 1.a., only 62% of the funds were spent for premium pay versus the required 65%, resulting in a shortage of premium pay of $57,700. • At one location, per Exhibit A, paragraph 1.b., one employee’s salary exceeded the limit of $25,000 allowable to be funded by the award by $1,725. Total expenses subject to the requirements of Exhibit A of the grant agreement were $2,105,470, representing 44% of total federal expenditures of $4,798,357. For Assistance Listing No. 21.027, total expenses for Ascension Living, Illinois, were $3,474,484, representing 72% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. St. Agnes Healthcare, Inc., Maryland – For two (totaling $4,526) of ten (totaling $21,950) (11%) payroll transactions sampled during the fiscal year, the employee’s timecards did not have evidence of review and approval by the employee’s manager for two months. For Assistance Listing No. 21.027, total payroll costs for the Maryland location were $113,188, representing 2% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living, Illinois – Ascension Living should implement internal controls to review the limitations requirement included in Exhibit A of the grant agreement and that the requirements are met prior to drawing down funds, required communication with the grantor is submitted, and required analysis is performed to be in compliance with the terms and conditions of the grant agreements. St. Agnes Healthcare, Inc., Maryland – The System should reinforce the importance of adhering to its internal controls over the review and approval of timecards. Views of responsible officials: Ascension Living management acknowledges that internal controls were not working effectively regarding review of the calculated limitations and allocations. Management has reserved the questioned costs and has communicated with the State on their desired method of repayment. For future grants, Ascension Living will implement controls for appropriate review and approval and to have a secondary review to validate calculations. St. Agnes Healthcare, Inc., Maryland - This finding pertains to retroactive grants where expenses were incurred in previous periods but were subsequently eligible for grant reimbursement. Management is working on creating a report to identify timecards lacking manager approval for exclusion as allowable grant expenses. Grant Accounting is incorporating a Time and Effort tracking feature, a separate approval control to mitigate the issue of timecards lacking manager approval.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The terms and conditions of the pass-through agreements with the states required the submission of the following special reports during the fiscal year. See table/chart in the finding Condition: The Quarterly Reimbursement Certifications and Quarterly Metrics Reports required by the state of Illinois were not submitted timely for various quarters during fiscal year 2023. The Quarterly Progress and Performance Metrics Report required by the state of Maryland was filed with incomplete information. Cause:Internal controls were not effective to ensure submission of the reports in accordance with the due dates under the pass-through agreement with the State of Illinois. In addition, internal controls were not effective to ensure all required data is reported on the reports required by the state of Maryland. Effect or potential effect: The System and Ascension Living did not file reports with the state of Illinois on a timely basis and was not in compliance with the terms and conditions of the federal program reporting requirements for the state of Maryland. Questioned costs: None. Context: 15 reports out of 21 required report submissions for the Illinois market were not submitted or submitted late. 1 report required for submission for the Maryland market did not include a required key year-to-date data field required by the state of Maryland. St. Agnes Healthcare, Inc., Maryland and Ascension Living, Illinois federal expenditures totaled $164,195 and $4,474,484, respectively, representing 3% and 93%, respectively, of total federal expenditures for Assistance Listing No. 21.027 of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The System should implement an internal control over the monitoring of due dates of all reports required to be submitted under the federal program to ensure they are submitted timely. The System should ensure internal controls over the review of required reports are enhanced to include review of key data. Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, the System will reinforce the importance to operations of oversight and accountability to submit required reports.

Information of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CRF Subpart E section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; and (g) be adequately documented.”In addition, per the State of Illinois, Department of Healthcare and Family Services and Presence Senior Services Agreement No. ARPA230050, Nazarethville Retirement Home Agreement No. ARPA230159, and Presence Life Connections Agreement No. ARPA230263, Exhibit A requires the awards pursuant to this program to comply with the following criteria: “1. 65% of the funds awarded under this grant shall comply with the following criteria. a) Shall be expended only for premium pay for eligible workers; in addition to any wages or remuneration the eligible worker has already received; and shall be subject to the other requirements and limitations set forth in the American Rescue Plan Act of 2021 and related federal guidance. b) Upon receipt of funds, recipients shall distribute funds such that eligible workers receive an amount up to $13 per hour, but no more than $25,000 for the duration of the program. Recipients shall provide a written certification to the Department acknowledging compliance with this paragraph. d) Each recipient under this paragraph shall submit appropriate documentation acknowledging compliance with State and federal law. For purposes of this section, “eligible worker” means a permanent staff member, regardless of union affiliation, of a facility licensed by the Department of Public Health under the Nursing Home Care Act as a skilled nursing facility or intermediate care facility engaged in “essential work”, as defined by Section 9901 of the American Rescue Plan Act of 2021 and related federal guidance, as well as whose total pay is below 150% of the average annual wage for all occupations in the worker’s county of residence, as defined by the Bureau of Labor Statistics Occupational Employment and Wage Statistics; or is not exempt from the federal Fair Labor Standards Act overtime provisions.” Condition: Illinois – Internal controls over the review and approval of program expenditures for allowability and period of performance under the federal program were not in place for Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) administering the federal program.Illinois – Nazarethville Retirement Home (Agreement No. ARPA230159) did not meet the criteria per Exhibit A, paragraph 1.a. In addition, Presence Senior Services (Agreement No. ARPA230050), Nazarethville Retirement Home (Agreement No. ARPA230159), and Presence Life Connections (Agreement No. ARPA230263) did not comply with the criteria per Exhibit A, paragraphs 1.b and 1.d. St. Agnes Healthcare, Inc., Maryland – Timecards for employees that were submitted for substantiation of funding for the federal program were not consistently reviewed and approved. Cause: Ascension Living, Illinois: •Ascension Living did not have effective internal controls in place over the review and approval of expenses and period of performance for certain locations administering the grant. •Ascension Living did not have internal controls in place to review and approve the requirements in Exhibit A and the analysis performed over the requirements included in Exhibit A of the program grant agreements. St. Agnes Healthcare, Inc., Maryland – Timecards were processed without manager approval. Effect or potential effect: Expenses may be charged to the federal award that are not in compliance with the federal or pass-through grant agreement. The System was not in noncompliance with the terms and conditions of the federal program. Questioned costs: $59,425 – Assistance Listing No. 21.027, Pass-Through Award Number ARPA230050 Context: Ascension Living, Illinois: • At one location, per Exhibit A, paragraph 1.a., only 62% of the funds were spent for premium pay versus the required 65%, resulting in a shortage of premium pay of $57,700. • At one location, per Exhibit A, paragraph 1.b., one employee’s salary exceeded the limit of $25,000 allowable to be funded by the award by $1,725. Total expenses subject to the requirements of Exhibit A of the grant agreement were $2,105,470, representing 44% of total federal expenditures of $4,798,357. For Assistance Listing No. 21.027, total expenses for Ascension Living, Illinois, were $3,474,484, representing 72% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. St. Agnes Healthcare, Inc., Maryland – For two (totaling $4,526) of ten (totaling $21,950) (11%) payroll transactions sampled during the fiscal year, the employee’s timecards did not have evidence of review and approval by the employee’s manager for two months. For Assistance Listing No. 21.027, total payroll costs for the Maryland location were $113,188, representing 2% of total federal expenditures of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living, Illinois – Ascension Living should implement internal controls to review the limitations requirement included in Exhibit A of the grant agreement and that the requirements are met prior to drawing down funds, required communication with the grantor is submitted, and required analysis is performed to be in compliance with the terms and conditions of the grant agreements. St. Agnes Healthcare, Inc., Maryland – The System should reinforce the importance of adhering to its internal controls over the review and approval of timecards. Views of responsible officials: Ascension Living management acknowledges that internal controls were not working effectively regarding review of the calculated limitations and allocations. Management has reserved the questioned costs and has communicated with the State on their desired method of repayment. For future grants, Ascension Living will implement controls for appropriate review and approval and to have a secondary review to validate calculations. St. Agnes Healthcare, Inc., Maryland - This finding pertains to retroactive grants where expenses were incurred in previous periods but were subsequently eligible for grant reimbursement. Management is working on creating a report to identify timecards lacking manager approval for exclusion as allowable grant expenses. Grant Accounting is incorporating a Time and Effort tracking feature, a separate approval control to mitigate the issue of timecards lacking manager approval.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Internal controls over suspension and debarment related to new vendor set up were not in place for Ascension Living. Specifically, documentation was not retained evidencing the review of new vendors for suspension and debarment prior to adding them into MatrixCare, Ascension Living’s current vendor management platform.The System has an internal control to review the accuracy of the vendor files transferred from the System’s vendor management system to ProviderTrust, the System’s third-party vendor engaged to perform its suspension and debarment review. The review of the completeness and accuracy of the data transferred to ProviderTrust was only performed for three of the twelve months during fiscal year 2023. The System has several IT applications that contain source vendor listings. Internal controls were not in place over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment (Ascension Living, Illinois). Cause: Management at Ascension Living did not have a requirement to retain the supporting documentation evidencing the review of new vendors for suspension and debarment. The System’s internal control over the review of the accuracy of the data transfer to ProviderTrust was not designed to review the completeness and accuracy of the data each time it is transferred to the third-party vendor. Internal controls were not in place at Ascension Living over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment. Effect or potential effect: New vendors may be used that are suspended or debarred. Suspension and debarment vendor files provided to the third-party vendor may not be accurate or complete. The data from MatrixCare transferred to the third-party vendor for suspension and debarment may not be complete and accurate. Federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For Assistance Listing No. 21.027, procurement expenditures subject to suspension and debarment review for Ascension Living, Illinois, totaled $1,369,015, which represents approximately 29% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Total federal portion of procurement expenditures subject to suspension and debarment review was $2,279,109, which represents approximately 47% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living should formalize the review and approval process of new vendors for suspension and debarment by authorized individuals that would include retention of evidence of the review, including documentation of the elements of the review process validated by the reviewer. The System should develop internal controls to ensure the integrity of data transfer to the third-party vendor is validated each time the data is transferred. Views of responsible officials: Ascension Living will provide education to their associates performing initial suspension and debarment screening as part of onboarding control activities to retain evidence of their review and the supporting documentation. Management will reassess controls over the data transfer application used to send the vendor data file to the third-party vendor, ProviderTrust. The System will explore implementing compensating controls for MatrixCare. The application is anticipated to be sunset in early 2025, when the process is migrated to Oracle Cloud and the established ProviderTrust processes.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The terms and conditions of the pass-through agreements with the states required the submission of the following special reports during the fiscal year. See table/chart in the finding Condition: The Quarterly Reimbursement Certifications and Quarterly Metrics Reports required by the state of Illinois were not submitted timely for various quarters during fiscal year 2023. The Quarterly Progress and Performance Metrics Report required by the state of Maryland was filed with incomplete information. Cause:Internal controls were not effective to ensure submission of the reports in accordance with the due dates under the pass-through agreement with the State of Illinois. In addition, internal controls were not effective to ensure all required data is reported on the reports required by the state of Maryland. Effect or potential effect: The System and Ascension Living did not file reports with the state of Illinois on a timely basis and was not in compliance with the terms and conditions of the federal program reporting requirements for the state of Maryland. Questioned costs: None. Context: 15 reports out of 21 required report submissions for the Illinois market were not submitted or submitted late. 1 report required for submission for the Maryland market did not include a required key year-to-date data field required by the state of Maryland. St. Agnes Healthcare, Inc., Maryland and Ascension Living, Illinois federal expenditures totaled $164,195 and $4,474,484, respectively, representing 3% and 93%, respectively, of total federal expenditures for Assistance Listing No. 21.027 of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The System should implement an internal control over the monitoring of due dates of all reports required to be submitted under the federal program to ensure they are submitted timely. The System should ensure internal controls over the review of required reports are enhanced to include review of key data. Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, the System will reinforce the importance to operations of oversight and accountability to submit required reports.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Internal controls over suspension and debarment related to new vendor set up were not in place for Ascension Living. Specifically, documentation was not retained evidencing the review of new vendors for suspension and debarment prior to adding them into MatrixCare, Ascension Living’s current vendor management platform.The System has an internal control to review the accuracy of the vendor files transferred from the System’s vendor management system to ProviderTrust, the System’s third-party vendor engaged to perform its suspension and debarment review. The review of the completeness and accuracy of the data transferred to ProviderTrust was only performed for three of the twelve months during fiscal year 2023. The System has several IT applications that contain source vendor listings. Internal controls were not in place over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment (Ascension Living, Illinois). Cause: Management at Ascension Living did not have a requirement to retain the supporting documentation evidencing the review of new vendors for suspension and debarment. The System’s internal control over the review of the accuracy of the data transfer to ProviderTrust was not designed to review the completeness and accuracy of the data each time it is transferred to the third-party vendor. Internal controls were not in place at Ascension Living over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment. Effect or potential effect: New vendors may be used that are suspended or debarred. Suspension and debarment vendor files provided to the third-party vendor may not be accurate or complete. The data from MatrixCare transferred to the third-party vendor for suspension and debarment may not be complete and accurate. Federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For Assistance Listing No. 21.027, procurement expenditures subject to suspension and debarment review for Ascension Living, Illinois, totaled $1,369,015, which represents approximately 29% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Total federal portion of procurement expenditures subject to suspension and debarment review was $2,279,109, which represents approximately 47% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living should formalize the review and approval process of new vendors for suspension and debarment by authorized individuals that would include retention of evidence of the review, including documentation of the elements of the review process validated by the reviewer. The System should develop internal controls to ensure the integrity of data transfer to the third-party vendor is validated each time the data is transferred. Views of responsible officials: Ascension Living will provide education to their associates performing initial suspension and debarment screening as part of onboarding control activities to retain evidence of their review and the supporting documentation. Management will reassess controls over the data transfer application used to send the vendor data file to the third-party vendor, ProviderTrust. The System will explore implementing compensating controls for MatrixCare. The application is anticipated to be sunset in early 2025, when the process is migrated to Oracle Cloud and the established ProviderTrust processes.

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 Pass-Through Grantor: Mayor and City Council of Baltimore, Through MONSE Ascension Ministry Market: Maryland Pass-Through Award Number: Not applicable Pass-Through Award Period: 07/01/2022-06/30/2023 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The terms and conditions of the pass-through agreements with the states required the submission of the following special reports during the fiscal year. See table/chart in the finding Condition: The Quarterly Reimbursement Certifications and Quarterly Metrics Reports required by the state of Illinois were not submitted timely for various quarters during fiscal year 2023. The Quarterly Progress and Performance Metrics Report required by the state of Maryland was filed with incomplete information. Cause:Internal controls were not effective to ensure submission of the reports in accordance with the due dates under the pass-through agreement with the State of Illinois. In addition, internal controls were not effective to ensure all required data is reported on the reports required by the state of Maryland. Effect or potential effect: The System and Ascension Living did not file reports with the state of Illinois on a timely basis and was not in compliance with the terms and conditions of the federal program reporting requirements for the state of Maryland. Questioned costs: None. Context: 15 reports out of 21 required report submissions for the Illinois market were not submitted or submitted late. 1 report required for submission for the Maryland market did not include a required key year-to-date data field required by the state of Maryland. St. Agnes Healthcare, Inc., Maryland and Ascension Living, Illinois federal expenditures totaled $164,195 and $4,474,484, respectively, representing 3% and 93%, respectively, of total federal expenditures for Assistance Listing No. 21.027 of $4,798,357 for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: The System should implement an internal control over the monitoring of due dates of all reports required to be submitted under the federal program to ensure they are submitted timely. The System should ensure internal controls over the review of required reports are enhanced to include review of key data. Views of responsible officials: Ascension Living management acknowledges that nine reports were not submitted to the State as required by the grant terms. Ascension Living management will coordinate with the State representatives regarding any past reports that are needed and submit them timely according to the agreement requirements. The System implemented a team calendar that tracks due dates of all reports required to be submitted under federal and state programs. This calendar is accessible to all team members, including management. However, the System will reinforce the importance to operations of oversight and accountability to submit required reports.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.

Information of the federal program: Federal Grantor: United States Department of Housing and Urban Development Assistance Listing No.: 14.241, Housing Opportunities for Persons with AIDS Ascension Ministry Market: Illinois Pass-Through Grantor: AIDS Foundation of Chicago Federal Grantor: United States Department of Justice Assistance Listing No.: 16.560, National Institute of Justice Research, Evaluation, and Development Project Grants Ascension Ministry Market: Texas Federal Grantor: United States Department of Justice Assistance Listing No.: 16.710, Public Safety Partnership and Community Policing Grants Ascension Ministry Market: Illinois Pass-Through Grantor: The Village of Arlington Heights Police Department Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Ascension Ministry Market: Maryland Pass-Through Grantor: Mayor and City Council of Baltimore, through MONSE Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.650, Accountable Health Communities Ascension Ministry Market: Illinois Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.958, Block Grants for Community Mental Health Services Ascension Ministry Market: Illinois Pass-Through Grantor: The State of Illinois Department of Human Services Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency ManagementFederal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.039, Hazard Mitigation Grant Ascension Ministry Market: Florida Pass-Through Grantor: Florida Division of Emergency Management Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition: A grant with expenditures of $55,702 under Assistance Listing No. 14.241 was not included on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management; the final Schedule was corrected. (Alexian Brothers-Bonaventure House, Illinois) A grant with expenditures of $204,574 under Assistance Listing No. 16.560 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (Ascension Seton, Texas) Expenditures in the amount of $89,084 under Assistance Listing No. 16.710 were improperly classified as Assistance Listing No. 93.958; the final Schedule was corrected. (Presence Behavioral Health, Illinois) A grant with expenditures of $230,108 under Assistance Listing No. 21.027 was included on the preliminary Schedule and was subsequently excluded when it was identified as a beneficiary award and not a subrecipient award; the final Schedule was corrected (Ascension Via Christi Hospitals Wichita, Inc., Kansas). A grant with expenditures of $164,195 under Assistance Listing No. 21.027 was not included on the preliminary Schedule provided by management; the final Schedule was corrected. (St. Agnes Healthcare, Inc., Maryland) Expenditures under Assistance Listing No. 93.650 were reported twice on the preliminary Schedule, resulting in overstatement of $314,551; the final Schedule was corrected. (Alexian Brothers Hospital Network, Illinois) A grant with expenditures of $232,713 under Assistance Listing No. 97.039 was misclassified as Assistance Listing No. 97.036; the final Schedule was corrected. (St. Vincent’s Health System, Florida) Cause: Ascension’s (the System) internal controls in place over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards. Effect or Potential Effect: Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes. Questioned costs: None. Context:The table below shows the preliminary and adjusted assistance listing on the Schedule. See table/chart in the finding. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Management should implement more robust internal controls to ensure the assistance listing numbers are appropriately listed on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule. Views of responsible officials: The System will enhance grant management award processes by revising its onboarding procedures and add additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the SEFA reporting totals to facilitate accurate reporting. Award amounts were changed on the SEFA reporting schedules after management’s review was executed. Management will implement preventive controls to lock down market SEFA templates after management final review.