Audit 304032

Federal Program – COVID-19 Provider Relief Fund, ALN 93.498, Award Year 2021 Criteria or specific requirement – Activities Allowed/Allowable Costs and Reporting– Pub. L. No. 116-136, 134 Stat. 563 Condition – Lost revenues reported to Health Resources and Services Administrator (HRSA) were not in accordance with Pub L. No. 116-136, 134 Stat. 563. Questioned Costs – $893,925 was the total amount of lost revenues determined to be over-reported to the federal program. This was calculated by taking the difference between reported quarterly gross patient service revenues and estimated quarterly patient service revenues net of contractual adjustments from third-party payors and bad debt. Context – The Hospital calculated lost revenues using gross patient service revenues. Effect – Lost revenues reported to HRSA were overstated. Cause – The Hospital did not have effective internal control processes in place to ensure the accurate calculation and reporting of lost revenues. Changes to frequently asked questions and guidance from HRSA and management’s inexperience with the program requirements resulted in a material error under the program. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The Hospital should implement documented internal control processes specific to understanding and reporting of lost revenues, including review and oversight of data prior to submission. Views of Responsible Officials and Planned Corrective Actions – The Hospital will continue to monitor the Department of Health and Human Resources Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements and the most recently distributed Provider Relief Fund frequently asked questions, which provide details on requirements related to the program, including further updates as they may occur.

Federal Program – COVID-19 – Provider Relief Fund, ALN 93.498, Award Year 2021 Criteria or Specific Requirement – Activities Allowed/Allowable Costs and Reporting– Pub. L. No. 116-136, 134 Stat. 563 Condition – Expenditures reported to HRSA were not in accordance with Pub. L. No. 116-136, 134 Stat. 563. Questioned Costs – $674,508 was the amount of expenses determined to be overreported to the federal program due to failure to reduce expenses by the Hospital’s Medicare cost reimbursement percentage. This was calculated by multiplying total Provider Relief Fund expenses reported to HRSA for Period 1 ($1,258,957) by the Hospital’s Medicare cost reimbursement percentage (50.73%). Additionally, $5,974 was the amount determined to be over-reported to the federal program due to the inclusion of an expense for which the Hospital received a credit from the vendor. This was calculated by taking the difference between the expense used in reporting adjusted for the Medicare cost reimbursement percentage and the actual expense adjusted for the Medicare cost reimbursement percentage. Additionally, the lack of review, reconciliation, and detailed record-keeping resulted in the Hospital’s inability to provide a detailed listing of all expenses reported to HRSA. Context – The Hospital did not reduce expenses included in the Hospital’s portal submission by its Medicare cost reimbursement percentage resulting in a testing population that did not agree to expenses reported. At least one expense included in the testing population was not reduced by a credit received from the vendor. Effect – Expenditures reported to HRSA were overstated. Cause – The Hospital did not have effective internal control processes in place to ensure the accurate review and reporting of program expenditures. Changes to frequently asked questions and guidance from HRSA and management’s inexperience with the program requirements resulted in an error of expenditures under the program. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The Hospital should implement documented internal control processes specific to understanding the reporting of program expenditures, including review and oversight of data uploads prior to submission. Views of Responsible Officials and Planned Corrective Actions – The Hospital will continue to monitor the Department of Health and Human Resources Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements and the most recently distributed Provider Relief Fund frequently asked questions, which provide details on requirements related to the program, including further updates as they may occur.

Federal Program – COVID-19 Provider Relief Fund, ALN 93.498, Award Year 2021 Criteria or specific requirement – Activities Allowed/Allowable Costs and Reporting– Pub. L. No. 116-136, 134 Stat. 563 Condition – Lost revenues reported to Health Resources and Services Administrator (HRSA) were not in accordance with Pub L. No. 116-136, 134 Stat. 563. Questioned Costs – $893,925 was the total amount of lost revenues determined to be over-reported to the federal program. This was calculated by taking the difference between reported quarterly gross patient service revenues and estimated quarterly patient service revenues net of contractual adjustments from third-party payors and bad debt. Context – The Hospital calculated lost revenues using gross patient service revenues. Effect – Lost revenues reported to HRSA were overstated. Cause – The Hospital did not have effective internal control processes in place to ensure the accurate calculation and reporting of lost revenues. Changes to frequently asked questions and guidance from HRSA and management’s inexperience with the program requirements resulted in a material error under the program. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The Hospital should implement documented internal control processes specific to understanding and reporting of lost revenues, including review and oversight of data prior to submission. Views of Responsible Officials and Planned Corrective Actions – The Hospital will continue to monitor the Department of Health and Human Resources Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements and the most recently distributed Provider Relief Fund frequently asked questions, which provide details on requirements related to the program, including further updates as they may occur.

Federal Program – COVID-19 – Provider Relief Fund, ALN 93.498, Award Year 2021 Criteria or Specific Requirement – Activities Allowed/Allowable Costs and Reporting– Pub. L. No. 116-136, 134 Stat. 563 Condition – Expenditures reported to HRSA were not in accordance with Pub. L. No. 116-136, 134 Stat. 563. Questioned Costs – $674,508 was the amount of expenses determined to be overreported to the federal program due to failure to reduce expenses by the Hospital’s Medicare cost reimbursement percentage. This was calculated by multiplying total Provider Relief Fund expenses reported to HRSA for Period 1 ($1,258,957) by the Hospital’s Medicare cost reimbursement percentage (50.73%). Additionally, $5,974 was the amount determined to be over-reported to the federal program due to the inclusion of an expense for which the Hospital received a credit from the vendor. This was calculated by taking the difference between the expense used in reporting adjusted for the Medicare cost reimbursement percentage and the actual expense adjusted for the Medicare cost reimbursement percentage. Additionally, the lack of review, reconciliation, and detailed record-keeping resulted in the Hospital’s inability to provide a detailed listing of all expenses reported to HRSA. Context – The Hospital did not reduce expenses included in the Hospital’s portal submission by its Medicare cost reimbursement percentage resulting in a testing population that did not agree to expenses reported. At least one expense included in the testing population was not reduced by a credit received from the vendor. Effect – Expenditures reported to HRSA were overstated. Cause – The Hospital did not have effective internal control processes in place to ensure the accurate review and reporting of program expenditures. Changes to frequently asked questions and guidance from HRSA and management’s inexperience with the program requirements resulted in an error of expenditures under the program. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The Hospital should implement documented internal control processes specific to understanding the reporting of program expenditures, including review and oversight of data uploads prior to submission. Views of Responsible Officials and Planned Corrective Actions – The Hospital will continue to monitor the Department of Health and Human Resources Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements and the most recently distributed Provider Relief Fund frequently asked questions, which provide details on requirements related to the program, including further updates as they may occur.