Audit 299676

FY End
2023-06-30
Total Expended
$243.36M
Findings
4
Programs
74
Organization: Trinity Health (MI)
Year: 2023 Accepted: 2024-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
387562 2023-002 - - H
387563 2023-003 - - B
964004 2023-002 - - H
964005 2023-003 - - B

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $126.50M Yes 0
84.268 Federal Direct Student Loans $2.96M - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $2.00M Yes 1
93.261 National Diabetes Prevention Program: Preventing Type 2 Diabetes Among People at High Risk $1.88M Yes 0
84.063 Federal Pell Grant Program $1.65M - 0
84.425 Education Stabilization Fund $1.11M - 0
93.074 Hospital Preparedness Program (hpp) and Public Health Emergency Preparedness (phep) Aligned Cooperative Agreements $609,919 - 0
16.575 Crime Victim Assistance $594,600 - 0
93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services $489,220 - 0
93.650 Accountable Health Communities $430,090 - 0
93.917 Hiv Care Formula Grants $397,044 - 0
93.969 Pphf Geriatric Education Centers $353,271 - 0
93.150 Projects for Assistance in Transition From Homelessness (path) $342,150 - 0
93.778 Medical Assistance Program $325,526 - 0
93.889 National Bioterrorism Hospital Preparedness Program $292,008 - 0
14.241 Housing Opportunities for Persons with Aids $261,942 - 0
14.267 Continuum of Care Program $259,663 - 0
93.011 National Organizations of State and Local Officials $257,306 - 0
93.994 Maternal and Child Health Services Block Grant to the States $216,013 - 0
14.231 Emergency Solutions Grant Program $197,000 - 0
93.604 Assistance for Torture Victims $183,095 - 0
93.276 Drug-Free Communities Support Program Grants $174,133 - 0
97.024 Emergency Food and Shelter National Board Program $174,078 - 0
93.914 Hiv Emergency Relief Project Grants $152,809 - 0
93.667 Social Services Block Grant $152,319 - 0
21.019 Coronavirus Relief Fund $102,179 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $100,527 - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $92,190 - 0
93.788 Opioid Str $80,483 - 0
84.007 Federal Supplemental Educational Opportunity Grants $78,897 - 0
93.359 Nurse Education, Practice Quality and Retention Grants $78,672 - 0
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $75,000 - 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $63,556 Yes 0
93.940 Hiv Prevention Activities_health Department Based $54,871 - 0
93.461 Covid-19 Testing for the Uninsured $52,956 - 0
93.958 Block Grants for Community Mental Health Services $50,000 - 0
16.838 Comprehensive Opioid Abuse Site-Based Program $47,795 - 0
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $46,713 - 0
16.831 Children of Incarcerated Parents $43,964 - 0
93.301 Small Rural Hospital Improvement Grant Program $39,200 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $37,972 - 0
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $37,803 - 0
93.399 Cancer Control $37,649 - 0
16.588 Violence Against Women Formula Grants $36,779 - 0
93.310 Trans-Nih Research Support $26,549 - 0
14.218 Community Development Block Grants/entitlement Grants $26,000 - 0
93.268 Immunization Cooperative Agreements $24,819 - 0
93.747 Elder Abuse Prevention Interventions Program $22,175 - 0
93.247 Advanced Nursing Education Grant Program $21,728 - 0
93.069 Public Health Emergency Preparedness $19,300 - 0
10.558 Child and Adult Care Food Program $16,918 - 0
16.529 Education, Training, and Enhanced Services to End Violence Against and Abuse of Women with Disabilities $16,197 - 0
93.839 Blood Diseases and Resources Research $15,000 - 0
93.364 Nursing Student Loans $14,750 - 0
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $14,556 - 0
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $14,003 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $11,276 - 0
84.033 Federal Work-Study Program $9,484 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $9,300 - 0
16.017 Sexual Assault Services Formula Program $8,391 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $6,965 - 0
93.395 Cancer Treatment Research $4,847 - 0
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $4,568 - 0
20.600 State and Community Highway Safety $4,133 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $4,125 - 0
93.837 Cardiovascular Diseases Research $4,000 - 0
93.566 Refugee and Entrant Assistance_state Administered Programs $3,427 - 0
93.283 Centers for Disease Control and Prevention_investigations and Technical Assistance $3,300 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2,633 - 0
93.697 Covid-19 Testing for Rural Health Clinics $2,037 - 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $1,975 - 0
93.575 Child Care and Development Block Grant $1,603 - 0
93.866 Aging Research $1,558 - 0
93.879 Medical Library Assistance $1,200 - 0

Contacts

Name Title Type
KCBGNFJGK478 Kim McCarthy Auditee
7343430830 Melissa Jagst Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF ACCOUNTING Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the “Schedule” or “SEFA”) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs – The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the “Schedule” or “SEFA”) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs – The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies.
Title: EXPENDITURES AND OTHER REPORTING Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the “Schedule” or “SEFA”) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs – The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Corporation’s consolidated financial statements include, for the year ended June 30, 2023, the operations of Saint Joseph’s Tower, Inc. (“Tower”), a subsidiary of Trinity Continuing Care Services. Tower reported total expenditures of federal awards of $3,402,821 for the year ended June 30, 2023. Included in these total expenditures is $2,786,851, which represents the outstanding mortgage balances insured under the Federal Housing Administration’s (“FHA”) Section 202 Supportive Housing for the Elderly. In addition, Tower earned $615,970 of its revenues in the year ended June 30, 2023, from the U.S. Department of Housing and Urban Development under the terms of the Housing Assistance Payment contracts. The accompanying consolidated SEFA does not include the federal awards activity of Tower because the federal expenditures were included in a separate audit report in accordance with the Uniform Guidance. The Corporation’s consolidated financial statements include the operations of Saint Joseph’s Mercy Care Services, Inc. (“SJMCS”) for the year ended June 30, 2023. SJMCS reported total expenditures of federal awards of $13,655,143 for the year ended June 30, 2023. The accompanying SEFA does not include the federal award activity of SJMCS because the federal expenditures were included in a separate audit report in accordance with the Uniform Guidance. The Corporation’s consolidated financial statements include the operations of Trinity Health Of New England, Inc. (“THOfNE”) for the year ended June 30, 2023. THOfNE recorded total expenditures of federal awards of $16,218,331 for the year ended June 30, 2023. Included in these total expenditures is $3,739,666, which represents expenditures of Mercy Hospital, Inc. & Subsidiaries. THOfNE’s fiscal year end is September 30 and THOfNE’s consolidated financial statements and schedule of Federal Expenditures will be audited separately for the year ended September 30, 2023. Accordingly, the federal expenditures were included in a separate audit report in accordance with the Uniform Guidance. As discussed in Note 3 of the consolidated financial statements, the Corporation underwent several acquisitions during the fiscal year ended June 30, 2023. As a result of these acquisitions, the Corporation obtained approvals from funding agencies to include all federal expenditures prior to the date of the acquisitions in the accompanying SEFA. The amounts of the pre-acquisition expenditures from July 1, 2022 to the acquisition date included in the SEFA are shown below.
Title: LOAN PROGRAMS Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the “Schedule” or “SEFA”) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs – The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The loan program listed below is administered directly by the Corporation. The balance relating to this program is included in the Corporation’s consolidated financial statements.
Title: PROVIDER RELIEF FUNDS Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the “Schedule” or “SEFA”) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs – The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Provider Relief Funds included in the Schedule were received by the following entities (legal name and tax identification number):
Title: COMMITMENTS AND CONTINGENCIES Accounting Policies: The accompanying Consolidated Supplemental Schedule of Expenditures of Federal Awards (the “Schedule” or “SEFA”) includes the federal grant activity of Trinity Health under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). The Schedule is presented using the accrual basis of accounting. Under this method, certain revenues are recognized when earned rather than when received and certain obligations are recognized when incurred rather than when they are paid. The accompanying SEFA includes the transactions of all federal awards of Trinity Health, except as described in Note 2. Federal awards received directly from federal agencies, as well as federal awards passed through other agencies, are included in the Schedule. Indirect Costs – The Corporation does not elect to use the de minimis indirect cost rate allowed under the Uniform Guidance. All rates used by the Corporation were approved by the awarding grant agencies. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Corporation participates in numerous state and federal grant programs, which are governed by various rules and regulations of the grantor agencies. Costs charged to the respective grant programs are subject to audit and adjustments by the grantor agencies. While the Corporation believes it has complied with all of the rules and regulations, to the extent that the Corporation has not complied with rules and regulations governing the grants, refund of any money received may be required and the collectability of any related receivable at June 30, 2023, may be impaired.

Finding Details

Condition – The Corporation did not report $2,000,000 of CSLFRF grant expenditures received by Saint Agnes Medical Center Fresno (“Fresno”) in the consolidated SEFA for the year ended June 30, 2022. This resulted in an understatement of CSLFRF expenditures on the Corporation’s SEFA for the year ended June 30, 2022. This issue was discussed with the County of Fresno, the pass-through granting agency for this program, who requested the omitted CSLFRF expenditures be tested and included in the Corporation’s SEFA for the year ended June 30, 2023. Criteria – According to § 200.510(b) of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, “The auditee must also prepare a schedule of expenditures of Federal awards 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.” Cause – The Fresno accounting department reported the CSLFRF grant to the Trinity Health Financial Reporting team incorrectly which resulted in the Fresno CSLFRF grant not being included in ALN 21.027, which was a major program for the year ended June 30, 2022. Effect – The Corporation’s SEFA for the year ended June 30, 2022 was understated by $2,000,000. Consequences for failure to comply with grant conditions may include a reduction of overall award and/or a restriction or reduction in future awards. Questioned costs – None Context – The Corporation did not report $2,000,000 of CSLFRF funds on its prior year SEFA. Repeat Finding from Prior Year – No Recommendation – The Corporation should institute additional policies and procedures to ensure grant expenditures reported by all locations are appropriately and completely included in the consolidated SEFA.
Condition – During the fiscal year ended June 30, 2023, Saint Agnes Medical Center Fresno (“Fresno”) was granted multiple project fundings under the Federal Emergency Management Agency’s (FEMA) Public Assistance grant program in response to the COVID-19 public health emergency. A total of $7,336,096 of FEMA assistance payments were received from the pass-through entity, California Governor's Office of Emergency Services. The eligible expenses that were obligated and disbursed for FEMA funding were incurred between March 20, 2020 and July 31, 2022, during which some of the expenses were also eligible for and reimbursed by another federal source of funding (COVID-19 Provider Relief Fund and American Rescue Plan – “PRF”). It was discovered that a total of $670,625 COVID-19 eligible expenses (i.e., occupancy and supplies) that were reimbursed by PRF were duplicative of those reported as project obligations to FEMA. Criteria – According to § 200.403(f) of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, “allowable costs must not be included as a cost of any other federally financed program in either the current or a prior period”. Cause – Prior to submitting the project applications to FEMA, the Fresno accounting department aggregated the total amount of eligible expenses available to be used for both the FEMA and PRF programs and determined that there were more expenses than the total award amounts for both programs. However, they did not review expenses by category and did not identify that expenses reported in the PRF portal filings in the occupancy and expense categories when combined with occupancy and supplies expenses reported for FEMA resulted in duplicative submission of some expenses. Effect – Fresno included certain occupancy and supplies expenses in both the PRF portal filing and the FEMA project application. Questioned costs – $670,625* **The amount is a questioned cost because there is no mechanism to correct the PRF portal filing to change the categories of expenses to reduce the occupancy and supplies category and increase another category for allowable expenses that have not yet been applied to PRF or FEMA grants. While the amount reported in the PRF portal for the categories of occupancy and supplies expense was overstated because certain costs were applied to FEMA awards, the total amount of expenses reported in the PRF portal requires no revision. Context – The Corporation included $670,625 out of $7,336,096 of expenses that were previously included in a PRF portal filing under the occupancy and supplies category. Fresno has $2,035,190 of additional PRF eligible expenses in other categories that have not been reimbursed by any other grant programs. Repeat Finding from Prior Year – No Recommendation – The Corporation should not only look at total expenses that are allowable for use under multiple federal sources of funding, but should also review the expenses at a detailed level to ensure that individual expenses are not double counted.
Condition – The Corporation did not report $2,000,000 of CSLFRF grant expenditures received by Saint Agnes Medical Center Fresno (“Fresno”) in the consolidated SEFA for the year ended June 30, 2022. This resulted in an understatement of CSLFRF expenditures on the Corporation’s SEFA for the year ended June 30, 2022. This issue was discussed with the County of Fresno, the pass-through granting agency for this program, who requested the omitted CSLFRF expenditures be tested and included in the Corporation’s SEFA for the year ended June 30, 2023. Criteria – According to § 200.510(b) of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, “The auditee must also prepare a schedule of expenditures of Federal awards 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.” Cause – The Fresno accounting department reported the CSLFRF grant to the Trinity Health Financial Reporting team incorrectly which resulted in the Fresno CSLFRF grant not being included in ALN 21.027, which was a major program for the year ended June 30, 2022. Effect – The Corporation’s SEFA for the year ended June 30, 2022 was understated by $2,000,000. Consequences for failure to comply with grant conditions may include a reduction of overall award and/or a restriction or reduction in future awards. Questioned costs – None Context – The Corporation did not report $2,000,000 of CSLFRF funds on its prior year SEFA. Repeat Finding from Prior Year – No Recommendation – The Corporation should institute additional policies and procedures to ensure grant expenditures reported by all locations are appropriately and completely included in the consolidated SEFA.
Condition – During the fiscal year ended June 30, 2023, Saint Agnes Medical Center Fresno (“Fresno”) was granted multiple project fundings under the Federal Emergency Management Agency’s (FEMA) Public Assistance grant program in response to the COVID-19 public health emergency. A total of $7,336,096 of FEMA assistance payments were received from the pass-through entity, California Governor's Office of Emergency Services. The eligible expenses that were obligated and disbursed for FEMA funding were incurred between March 20, 2020 and July 31, 2022, during which some of the expenses were also eligible for and reimbursed by another federal source of funding (COVID-19 Provider Relief Fund and American Rescue Plan – “PRF”). It was discovered that a total of $670,625 COVID-19 eligible expenses (i.e., occupancy and supplies) that were reimbursed by PRF were duplicative of those reported as project obligations to FEMA. Criteria – According to § 200.403(f) of the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, “allowable costs must not be included as a cost of any other federally financed program in either the current or a prior period”. Cause – Prior to submitting the project applications to FEMA, the Fresno accounting department aggregated the total amount of eligible expenses available to be used for both the FEMA and PRF programs and determined that there were more expenses than the total award amounts for both programs. However, they did not review expenses by category and did not identify that expenses reported in the PRF portal filings in the occupancy and expense categories when combined with occupancy and supplies expenses reported for FEMA resulted in duplicative submission of some expenses. Effect – Fresno included certain occupancy and supplies expenses in both the PRF portal filing and the FEMA project application. Questioned costs – $670,625* **The amount is a questioned cost because there is no mechanism to correct the PRF portal filing to change the categories of expenses to reduce the occupancy and supplies category and increase another category for allowable expenses that have not yet been applied to PRF or FEMA grants. While the amount reported in the PRF portal for the categories of occupancy and supplies expense was overstated because certain costs were applied to FEMA awards, the total amount of expenses reported in the PRF portal requires no revision. Context – The Corporation included $670,625 out of $7,336,096 of expenses that were previously included in a PRF portal filing under the occupancy and supplies category. Fresno has $2,035,190 of additional PRF eligible expenses in other categories that have not been reimbursed by any other grant programs. Repeat Finding from Prior Year – No Recommendation – The Corporation should not only look at total expenses that are allowable for use under multiple federal sources of funding, but should also review the expenses at a detailed level to ensure that individual expenses are not double counted.