FAC Explorer

Audit 300159

FY End
2023-06-30
Total Expended
$142.03M
Findings
2
Programs
17
Organization: Christus Health (TX)
Year: 2023 Accepted: 2024-03-28
Auditor: Ernst & Young LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
388425 2023-001 Material Weakness Yes A
964867 2023-001 Material Weakness Yes A

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distributions $125.49M Yes 1
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.64M Yes 0
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $1.51M - 0
93.697 Covid-19 Testing and Mitigation for Rural Health Clinics $900,000 - 0
93.650 Accountable Health Communities $393,459 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $224,692 - 0
93.155 Rural Health Research Centers $146,278 - 0
16.575 Crime Victim Assistance $91,151 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $88,506 - 0
93.395 Cancer Treatment Research $69,440 - 0
93.136 Injury Prevention and Control Research and State and Community Based Programs $50,000 - 0
93.393 Cancer Cause and Prevention Research $47,161 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $34,571 - 0
93.889 National Bioterrorism Hospital Preparedness Program $15,139 - 0
93.301 Small Rural Hospital Improvement Grant Program $10,990 - 0
93.667 Social Services Block Grant $6,490 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $4,578 - 0

Contacts

Name Title Type
C4A1GH8YACH4 Melissa Crenwelge-Nedbalek Auditee
4692822004 Debra Kohnle Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the Uniform Guidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contract With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. The accompanying schedule of expenditures of federal and state awards (the Schedule) includes the federal and state award activity of CHRISTUS Health under programs of the federal and state governments for the year ended June 30, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirments for Federal Awards (Uniform Guidance) and the Texas Grant Management Standards (TxGMS). Because the Schedule presents only a selected portion of the operations of CHRISTUS Health, it is not intended to and does not present the financial position, results of operation, changes in net assets, or cash flows of CHRISTUS Health.
Title: Nature of Activities Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the Uniform Guidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contract With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. CHRISTUS Health receives various grants to cover costs of specified programs. Final determination of eligibility of costs will be made by the grantors. Should any costs be found ineligible, CHRISTUS Health will be responsible for reimbursing the grantors for these amounts. Additionally, expenditures incurred for various programs may exceed the amounts awarded from the respective pass-through entity or agency. The amounts reported on the Schedule are limited to the award amounts. Amounts in excess of this amount are paid out of non-federal and non-state sources.
Title: Donated Personal Protective Equipment (unaudited) Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the Uniform Guidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contract With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. CHRISTUS Health did not receive any donated personal protective equipment from federal sources for the year ended June 30, 2023.
Title: Provider Relief Fund Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the Uniform Guidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contract With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. The Schedule includes grant activity related to the Department of Health and Human Services (HHS) Coronovirus Aid Relief and Economic Security (CARES) Act Assistance Listing Number 93.498. As required based on guidance in the 2023 OMB Compliance Supplement, the Schedule includes all funds received between July 1, 2021 and June 30, 2022, and expended by June 30, 2023, as reported to the Health Resources and Services Administration (HRSA) via the Provide Relief Fund Reporting Portal.
Title: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, the cost principles contained in the Uniform Guidance, 45 CFR, PART 75 APPENDIX IX, Principles for Determining Costs Applicable to Research and Development Under Grants and Contract With Hospitals, and TxGMS, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: CHRISTUS Health has negotiated multiple indirect cost rates for consolidated entities that have been eligible to negotiate a federal indirect cost rate with the Department of Health and Human Services (DHHS). However, not all awards presented in the Schedule include indirect expenses. Allowable indirect costs for each award are determined by the related terms and conditions developed by the awarding agency for each program. CHRISTUS Health has not elected to use the 10% de minimis cost rate allowed under Uniform Guidance. In accordance with guidance from the U.S. Department of Homeland Security, the amount presented on the SEFA for Assistance Listing Number 97.036 - COVID-19 - Disaster Grants - Public Assistance (Presidentially Declared Disasters), represents expenditures that were incurred as of the end of the fiscal year, related to project worksheets approved by the Federal Emergency Managment Agency (FEMA) during the fiscal year. CHRISTUS Health reported $12,627,715 in COVID-19 related funding from FEMA during the fiscal year ended June 30, 2023. Of this amount, $12,627,715 in expenditures were incurred prior to the beginning of the fiscal year.

Finding Details

Finding 2023-001
Section III – Federal Award Findings and Questioned Costs Finding 2023-001 – Internal Control Deficiency and Noncompliance over Activities Allowed or Unallowed Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID – 19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: January 1, 2020 – June 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 award states the recipient certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses and lost revenues that are attributable to coronavirus. Condition: CHRISTUS Health did not consistently retain documentation to evidence approval of certain expenses incurred related to COVID-19. Also, certain payroll expenses related to COVID-19 were calculated using current pay rates as opposed to pay rates in effect at the time the payroll expenses were incurred. Finding 2023-001 – Internal Control Deficiency and Noncompliance over Activities Cause: CHRISTUS Health did not have controls in place to ensure amounts recorded as COVID-19 related expenses were reviewed and approved. CHRISTUS Health did not use appropriate pay rates when calculating labor costs to treat COVID-19 patients in the provider relief fund report (the Portal Submission) submitted to Health Resource Services Administration (HRSA). Effect or potential effect: Lack of documentation of controls could lead to noncompliance. Charging expenses to the program using incorrect pay rates could result in overcharging the program. Questioned Costs: $237 Context: CHRISTUS Health reported $65,505,801 of total expenses for the Period 4 and 5 HRSA Portal Submissions relating to Provider Relief Funding (PRF) Phase 4 General Distributions and American Rescue Plan (ARP) Rural Payments. Because a material weakness was issued in the prior year related to lack of documentation of controls surrounding expenses, we did not test and rely on controls for expenses in the current audit as the finding had not been remediated for the entire audit period. We selected 95 disbursements from the $65,505,801 of total expenses reported. Total program related expenditures that were charged specifically to a COVID related Activity Code within the Payroll IT System were $3,166,654. Of the 95 selected disbursements, 10 disbursements related to the COVID Activity Code. For payroll costs charged to the COVID Activity code, the amount charged to the award was calculated using the actual hours incurred multiplied by the pay rate at the time the portal submission was prepared, instead of the pay rate in effect at the time the hours were incurred. The 10 selections totaled $11,759. We recalculated the amount charged to the program using the pay rates in effect at the time the hours were incurred resulting in four overcharges totaling $237, four undercharges totaling $846, and two correct charges in which the current pay rate happened to match the pay rate at the time the hours were incurred. Identification as a repeat finding, if applicable: The finding is a repeat finding of 2021-001 and 2022-001. Recommendation: CHRISTUS Health should refine its process to retain documentation evidencing that each expense charged to the program is reviewed and approved. Only actual expenses should be charged to the program. View of Responsible Officials: Management agrees with the finding and will implement corrective action.
Finding 2023-001
Section III – Federal Award Findings and Questioned Costs Finding 2023-001 – Internal Control Deficiency and Noncompliance over Activities Allowed or Unallowed Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID – 19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: January 1, 2020 – June 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 award states the recipient certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses and lost revenues that are attributable to coronavirus. Condition: CHRISTUS Health did not consistently retain documentation to evidence approval of certain expenses incurred related to COVID-19. Also, certain payroll expenses related to COVID-19 were calculated using current pay rates as opposed to pay rates in effect at the time the payroll expenses were incurred. Finding 2023-001 – Internal Control Deficiency and Noncompliance over Activities Cause: CHRISTUS Health did not have controls in place to ensure amounts recorded as COVID-19 related expenses were reviewed and approved. CHRISTUS Health did not use appropriate pay rates when calculating labor costs to treat COVID-19 patients in the provider relief fund report (the Portal Submission) submitted to Health Resource Services Administration (HRSA). Effect or potential effect: Lack of documentation of controls could lead to noncompliance. Charging expenses to the program using incorrect pay rates could result in overcharging the program. Questioned Costs: $237 Context: CHRISTUS Health reported $65,505,801 of total expenses for the Period 4 and 5 HRSA Portal Submissions relating to Provider Relief Funding (PRF) Phase 4 General Distributions and American Rescue Plan (ARP) Rural Payments. Because a material weakness was issued in the prior year related to lack of documentation of controls surrounding expenses, we did not test and rely on controls for expenses in the current audit as the finding had not been remediated for the entire audit period. We selected 95 disbursements from the $65,505,801 of total expenses reported. Total program related expenditures that were charged specifically to a COVID related Activity Code within the Payroll IT System were $3,166,654. Of the 95 selected disbursements, 10 disbursements related to the COVID Activity Code. For payroll costs charged to the COVID Activity code, the amount charged to the award was calculated using the actual hours incurred multiplied by the pay rate at the time the portal submission was prepared, instead of the pay rate in effect at the time the hours were incurred. The 10 selections totaled $11,759. We recalculated the amount charged to the program using the pay rates in effect at the time the hours were incurred resulting in four overcharges totaling $237, four undercharges totaling $846, and two correct charges in which the current pay rate happened to match the pay rate at the time the hours were incurred. Identification as a repeat finding, if applicable: The finding is a repeat finding of 2021-001 and 2022-001. Recommendation: CHRISTUS Health should refine its process to retain documentation evidencing that each expense charged to the program is reviewed and approved. Only actual expenses should be charged to the program. View of Responsible Officials: Management agrees with the finding and will implement corrective action.