Audit 300321

Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF), Assistance Listing number 93.498 Federal Agency: U.S. Department of Health and Human Services (HHS) Award Numbers: Various Award Period: January 1, 2020 through June 30, 2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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 PRF require the recipient to submit reports to the secretary of the U.S. Department of Health and Human Services (HHS) for each reporting period to ensure compliance with conditions that are imposed on the federal award, and such report shall be in such form, with such content, as specified by the secretary of HHS in program instructions directed to all recipients. Condition: Management did not sufficiently design internal controls to identify that documentation submitted in the HHS Reporting Portal for the Period 4 and Period 5 PRF General Distributions was not complete and accurate. Documentation to support TriHealth’s lost revenue calculation was not submitted for Period 4, and the supporting documentation submitted for Period 5 did not agree to Management’s lost revenue calculation. Cause: Management’s internal controls over the review and approval of the PRF reporting submissions in the HHS Reporting Portal and supporting documentation were not sufficiently robust to identify the exclusion of required supporting documentation and data errors within that supporting documentation. Effect or potential effect: Lack of sufficiently designed review and approval procedures pertaining to PRF reporting could have resulted in unallowable expenditures or unsupported lost revenue charged to the PRF program. Furthermore, the lack of precision in internal controls resulted in incomplete and inaccurate information submitted to the HHS Reporting Portal. Questioned costs: None. Context: We inspected the Period 4 and Period 5 PRF General Distribution reporting submissions, noting the necessary or accurate documentation was not submitted in the HHS Reporting Portal. Furthermore, the lost revenue detailed on the Period 4 and Period 5 PRF General Distribution reports did not agree to the TriHealth’s lost revenue calculation. However, based on Management's lost revenue calculation, including the updated lost revenue calculation addressing all data errors, TriHealth as sufficient lost revenue to support the Period 4 and Period 5 PRF expenditures. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should reassess the precision of its internal controls over the review and approval of program reports and the supporting documentation to ensure information reported is complete and accurate. Views of responsible officials: Management agrees with this finding and will update policies and procedures to ensure that a comprehensive review and approval process is applied consistently in the preparation of any future similar submissions.

Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF), Assistance Listing number 93.498 Federal Agency: U.S. Department of Health and Human Services (HHS) Award Numbers: Various Award Period: January 1, 2020 through June 30, 2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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 PRF require the recipient to submit reports to the secretary of the U.S. Department of Health and Human Services (HHS) for each reporting period to ensure compliance with conditions that are imposed on the federal award, and such report shall be in such form, with such content, as specified by the secretary of HHS in program instructions directed to all recipients. Condition: Management did not sufficiently design internal controls to identify that documentation submitted in the HHS Reporting Portal for the Period 4 and Period 5 PRF General Distributions was not complete and accurate. Documentation to support TriHealth’s lost revenue calculation was not submitted for Period 4, and the supporting documentation submitted for Period 5 did not agree to Management’s lost revenue calculation. Cause: Management’s internal controls over the review and approval of the PRF reporting submissions in the HHS Reporting Portal and supporting documentation were not sufficiently robust to identify the exclusion of required supporting documentation and data errors within that supporting documentation. Effect or potential effect: Lack of sufficiently designed review and approval procedures pertaining to PRF reporting could have resulted in unallowable expenditures or unsupported lost revenue charged to the PRF program. Furthermore, the lack of precision in internal controls resulted in incomplete and inaccurate information submitted to the HHS Reporting Portal. Questioned costs: None. Context: We inspected the Period 4 and Period 5 PRF General Distribution reporting submissions, noting the necessary or accurate documentation was not submitted in the HHS Reporting Portal. Furthermore, the lost revenue detailed on the Period 4 and Period 5 PRF General Distribution reports did not agree to the TriHealth’s lost revenue calculation. However, based on Management's lost revenue calculation, including the updated lost revenue calculation addressing all data errors, TriHealth as sufficient lost revenue to support the Period 4 and Period 5 PRF expenditures. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should reassess the precision of its internal controls over the review and approval of program reports and the supporting documentation to ensure information reported is complete and accurate. Views of responsible officials: Management agrees with this finding and will update policies and procedures to ensure that a comprehensive review and approval process is applied consistently in the preparation of any future similar submissions.