Item: 2022-002
Assistance Listing Number: 93.498
Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Federal Agency: U.S. Department of Health and Human Services
Award Year: Period 2 Funds – Period of Availability January 1, 2020 – December 31, 2021
Compliance Requirement: Reporting
Criteria or Specific Requirement: Management is responsible for reporting complete and accurate usage of Provider Relief Funds to the Health Resources & Services Administrator (“HRSA”) for each applicable period.
Condition: Certain unreimbursed expenditures, totaling $479,490, reported by management as qualified expenditures for Period 2 within the HRSA Reporting Portal were improperly reported as all being incurred in Q3 of 2020 when in fact a portion of the expenses we incurred through and should have been reported in Q1 2020, Q2 2020, Q4 2020, Q1, 2021, Q2, 2021, Q3 2021 and Q4, 2021. However, we noted that all qualified expenditures were still incurred within the proper period of performance. Additionally, management did not retain proper documentation of the review and approval of the reporting submitted to HRSA.
Cause: Touchstone Behavioral Health d/b/a Touchstone Health Services did not have sufficient controls designed to provide for the proper review and approval of the HRSA reporting to ensure expenses were properly reported in the correct period and to ensure that the final report was reviewed and approved prior to submission.
Effect: As a result of the error, the amount of qualifying expenses reported as incurred in Q3 2020 of the HRSA Reporting Portal was over-stated by $479,490 and the following quarters were understated as follows:
Q1 2020 - $22,833
Q2 2020 - $333,508
Q4 2020 - $22,283
Q1 2021 - $6,878
Q2 2021 - $18,679
Q3 2021 - $44,462
Q4 2021 - $30,847
However, we noted that all qualified expenditures were still incurred within the proper period of performance and that there we no effect on the final amount per the Schedule of Expenditures of Federal Awards as Touchstone Behavioral Health d/b/a Touchstone Health Services had sufficient unreimbursed expenditures in the remaining periods of availability. This was deemed to be a material weakness in internal control over compliance.
Questioned costs: n/a
Context: In the total population of unreimbursed expenditures totaling $479,490, we obtained the population detail noting expenditures from January 2020 through December 2021. We conducted a non-statistical sample of 17 non-payroll and 40 payroll related expenditures and noted the appropriate period of expenditure did not agree with the quarterly amounts reported to HRSA. However, these amounts were properly shown as expenditures of Period 2 funds.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: Management should implement controls to ensure the proper review and approval of federal award reporting to the federal awarding and to ensure the reporting is accurate. Management should also implement a review control such that an individual outside of the preparer reviews the federal award reporting.
Views of Responsible Officials: Management of Touchstone Behavioral Health d/b/a Touchstone Health Services concurs with the finding. See Corrective Action Plan.
Item: 2022-003
Assistance Listing Number: 93.498
Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Federal Agency: U.S. Department of Health and Human Services
Award Year: Period 2 Funds – Period of Availability January 1, 2020 – December 31, 2021
Compliance Requirement: Activities allowed or unallowed
Criteria or Specific Requirement: Management is responsible for Standards for Documentation that should be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition: Management did not retain proper documentation of the review and approval of certain allowable expenses.
Cause: Touchstone Behavioral Health d/b/a Touchstone Health Services did not have adequate internal controls in place to ensure sufficient documentation of the proper review and approval of expenses to the program was maintained.
Effect: Management was not able to support that certain expenses were reviewed and approved. This is deemed to be a material weakness in internal control over compliance.
Questioned costs: n/a
Context: We conducted a non-statistical sample of 17 non-payroll and 40 payroll related expenditures and noted 13 of the non-payroll and 8 of the payroll selections lacked proper documentation of management review and approval.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: Management should implement internal controls to ensure documentation is retained to support that expenses are properly reviewed and approved.
Views of Responsible Officials: Management of Touchstone Behavioral Health d/b/a Touchstone Health Services concurs with the finding. See Corrective Action Plan.
Item: 2022-002
Assistance Listing Number: 93.498
Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Federal Agency: U.S. Department of Health and Human Services
Award Year: Period 2 Funds – Period of Availability January 1, 2020 – December 31, 2021
Compliance Requirement: Reporting
Criteria or Specific Requirement: Management is responsible for reporting complete and accurate usage of Provider Relief Funds to the Health Resources & Services Administrator (“HRSA”) for each applicable period.
Condition: Certain unreimbursed expenditures, totaling $479,490, reported by management as qualified expenditures for Period 2 within the HRSA Reporting Portal were improperly reported as all being incurred in Q3 of 2020 when in fact a portion of the expenses we incurred through and should have been reported in Q1 2020, Q2 2020, Q4 2020, Q1, 2021, Q2, 2021, Q3 2021 and Q4, 2021. However, we noted that all qualified expenditures were still incurred within the proper period of performance. Additionally, management did not retain proper documentation of the review and approval of the reporting submitted to HRSA.
Cause: Touchstone Behavioral Health d/b/a Touchstone Health Services did not have sufficient controls designed to provide for the proper review and approval of the HRSA reporting to ensure expenses were properly reported in the correct period and to ensure that the final report was reviewed and approved prior to submission.
Effect: As a result of the error, the amount of qualifying expenses reported as incurred in Q3 2020 of the HRSA Reporting Portal was over-stated by $479,490 and the following quarters were understated as follows:
Q1 2020 - $22,833
Q2 2020 - $333,508
Q4 2020 - $22,283
Q1 2021 - $6,878
Q2 2021 - $18,679
Q3 2021 - $44,462
Q4 2021 - $30,847
However, we noted that all qualified expenditures were still incurred within the proper period of performance and that there we no effect on the final amount per the Schedule of Expenditures of Federal Awards as Touchstone Behavioral Health d/b/a Touchstone Health Services had sufficient unreimbursed expenditures in the remaining periods of availability. This was deemed to be a material weakness in internal control over compliance.
Questioned costs: n/a
Context: In the total population of unreimbursed expenditures totaling $479,490, we obtained the population detail noting expenditures from January 2020 through December 2021. We conducted a non-statistical sample of 17 non-payroll and 40 payroll related expenditures and noted the appropriate period of expenditure did not agree with the quarterly amounts reported to HRSA. However, these amounts were properly shown as expenditures of Period 2 funds.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: Management should implement controls to ensure the proper review and approval of federal award reporting to the federal awarding and to ensure the reporting is accurate. Management should also implement a review control such that an individual outside of the preparer reviews the federal award reporting.
Views of Responsible Officials: Management of Touchstone Behavioral Health d/b/a Touchstone Health Services concurs with the finding. See Corrective Action Plan.
Item: 2022-003
Assistance Listing Number: 93.498
Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Federal Agency: U.S. Department of Health and Human Services
Award Year: Period 2 Funds – Period of Availability January 1, 2020 – December 31, 2021
Compliance Requirement: Activities allowed or unallowed
Criteria or Specific Requirement: Management is responsible for Standards for Documentation that should be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition: Management did not retain proper documentation of the review and approval of certain allowable expenses.
Cause: Touchstone Behavioral Health d/b/a Touchstone Health Services did not have adequate internal controls in place to ensure sufficient documentation of the proper review and approval of expenses to the program was maintained.
Effect: Management was not able to support that certain expenses were reviewed and approved. This is deemed to be a material weakness in internal control over compliance.
Questioned costs: n/a
Context: We conducted a non-statistical sample of 17 non-payroll and 40 payroll related expenditures and noted 13 of the non-payroll and 8 of the payroll selections lacked proper documentation of management review and approval.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: Management should implement internal controls to ensure documentation is retained to support that expenses are properly reviewed and approved.
Views of Responsible Officials: Management of Touchstone Behavioral Health d/b/a Touchstone Health Services concurs with the finding. See Corrective Action Plan.