Audit 30529

Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (COVID-19 Uninsured Program) Award Period: January 1, 2022 through December 31, 2022 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).? Health and Human Services (HHS) ? Health Resources and Services and Administrative (HRSA) issued Terms and Conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (T&Cs) outlining requirements that recipients of funding from the HRSA COVID-19 Uninsured Program must comply with including the following sections: Testing Services, Treatment Services and Vaccine Administration, and General Provisions in FY2022 Consolidated Appropriations. Condition: Premier Health Partners and Subsidiaries? (the Company) did not appropriately design and execute internal control procedures to review for retroactive insurance that subsequently became effective for the date(s) of service on patient accounts previously billed to and reimbursed by the COVID-19 Uninsured Program. Cause: The Company did not design or execute internal controls to continually monitor the eligibility of accounts previously billed to and reimbursed by the program. While management has processes in place to review claims for potential insurance coverage prior to initial billing, there was no process established to subsequently identify alternative insurance coverage that could have become retroactively effective for accounts and rendered them ineligible for the Company to retain the reimbursement received under the program. Effect or potential effect: The Company could be in noncompliance with the HRSA COVID-19 Uninsured Program T&Cs. Patients may not have ultimately remained uninsured on their encounter date, and therefore the related encounter may have become ineligible for reimbursement under the HRSA COVID-19 Uninsured Program. Questioned costs: None. Context: We inquired of management, who indicated internal controls over the continued monitoring of the eligibility of previously reimbursed patient encounters were not effectively designed and were not operating effectively. Identification as a repeat finding, if applicable: Not applicable. Recommendation: As the HRSA COVID-19 Uninsured Program ceased accepting claims in March 2022, the Company no longer submits claims or receives reimbursement under the program. Therefore, management should complete a review of previously reimbursed claims to identify any with retroactively applied insurance that rendered the encounter ineligible to retain previously received reimbursement on the account, with any identified ineligible reimbursement refunded to the program. Designing and implementing internal control processes for ongoing retroactive insurance reviews is not deemed necessary given the closure of the program. Views of responsible officials: Management agrees with the finding and will complete a review of previously reimbursed claims from the HRSA COVID-19 Uninsured Program to identify any with retroactively applied insurance. Any identified ineligible reimbursements will be refunded to the program by December 31, 2023.

Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (COVID-19 Uninsured Program) Award Period: January 1, 2022 through December 31, 2022 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).? Health and Human Services (HHS) ? Health Resources and Services and Administrative (HRSA) issued Terms and Conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (T&Cs) outlining requirements that recipients of funding from the HRSA COVID-19 Uninsured Program must comply with including the following sections: Testing Services, Treatment Services and Vaccine Administration, and General Provisions in FY2022 Consolidated Appropriations. Condition: Premier Health Partners and Subsidiaries? (the Company) did not appropriately design and execute internal control procedures to review for retroactive insurance that subsequently became effective for the date(s) of service on patient accounts previously billed to and reimbursed by the COVID-19 Uninsured Program. Cause: The Company did not design or execute internal controls to continually monitor the eligibility of accounts previously billed to and reimbursed by the program. While management has processes in place to review claims for potential insurance coverage prior to initial billing, there was no process established to subsequently identify alternative insurance coverage that could have become retroactively effective for accounts and rendered them ineligible for the Company to retain the reimbursement received under the program. Effect or potential effect: The Company could be in noncompliance with the HRSA COVID-19 Uninsured Program T&Cs. Patients may not have ultimately remained uninsured on their encounter date, and therefore the related encounter may have become ineligible for reimbursement under the HRSA COVID-19 Uninsured Program. Questioned costs: None. Context: We inquired of management, who indicated internal controls over the continued monitoring of the eligibility of previously reimbursed patient encounters were not effectively designed and were not operating effectively. Identification as a repeat finding, if applicable: Not applicable. Recommendation: As the HRSA COVID-19 Uninsured Program ceased accepting claims in March 2022, the Company no longer submits claims or receives reimbursement under the program. Therefore, management should complete a review of previously reimbursed claims to identify any with retroactively applied insurance that rendered the encounter ineligible to retain previously received reimbursement on the account, with any identified ineligible reimbursement refunded to the program. Designing and implementing internal control processes for ongoing retroactive insurance reviews is not deemed necessary given the closure of the program. Views of responsible officials: Management agrees with the finding and will complete a review of previously reimbursed claims from the HRSA COVID-19 Uninsured Program to identify any with retroactively applied insurance. Any identified ineligible reimbursements will be refunded to the program by December 31, 2023.