Audit 306248

Assistance Listing, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan Rural Distribution (PRF) Federal Award Identification Number and Year N/A, 2021 Pass through Entity N/A, Direct funded Finding Type Material weakness and material noncompliance with laws and regulations Criteria Per the most recent Provider Relief Fund Distributions and American Rescue Plan Rural Distributions Post Payment Notice of Reporting Requirements, published by the U.S. Department of Health and Human Services (HHS), allowable expenses paid with general and targeted PRF distributions may be reported as a use of PRF funds, provided that the expenses have not been reimbursed by another source. Condition The Organization's controls in place for reporting submission did not identify that guidelines were not followed related to the reporting of expenses. Questioned Costs $5,703,280 Identification of How Questioned Costs Were Computed Questioned costs of $5,703,280 resulted from the Organization applying expenses that were already reimbursed through its Paycheck Protection Program (PPP) loan forgiveness application. Context The reporting submission for health care expenses did not follow the guidelines published by HHS. The Organization's Period 1 portal submission overstated expenses by $5,703,280, that were included within the Organization's PPP loan forgiveness application. These expenses should not have been included within the Period 1 submission. Due to the Organization having excess allowable health care expenses and lost revenue reported in the portal submission that could have been utilized to support the retention of the PRF funds, the Organization still had qualified expenditures to recognize all PRF payments received in Period 1. Cause and Effect The review process surrounding the expenses reported was not sufficient to ensure that the expenses were accurately reported. As a result, the report submitted was inaccurate. Recommendation We recommend the Organization enhance controls, including additional levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan The Organization accepts the finding and has implemented additional layers of review regarding expense submission to ensure the reports are submitted within the established guidelines. The submission was prepared by prior management that is no longer at the organization during a period of transition from the acquisition by Beacon. Subsequent reporting was performed for TRH by Beacon management after this initial submission and subsequent audits were performed with all findings resolved. As stated above, the Organization had sufficient additional expenditures and lost revenue from the COVID 19 pandemic and there are no resulting PRF recognition issues.

Assistance Listing, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan Rural Distribution (PRF) Federal Award Identification Number and Year N/A, 2021 Pass through Entity N/A, Direct funded Finding Type Material weakness and material noncompliance with laws and regulations Criteria Per the most recent Provider Relief Fund Distributions and American Rescue Plan Rural Distributions Post Payment Notice of Reporting Requirements, published by the U.S. Department of Health and Human Services (HHS), allowable expenses paid with general and targeted PRF distributions may be reported as a use of PRF funds, provided that the expenses have not been reimbursed by another source. Condition The Organization's controls in place for reporting submission did not identify that guidelines were not followed related to the reporting of expenses. Questioned Costs $5,703,280 Identification of How Questioned Costs Were Computed Questioned costs of $5,703,280 resulted from the Organization applying expenses that were already reimbursed through its Paycheck Protection Program (PPP) loan forgiveness application. Context The reporting submission for health care expenses did not follow the guidelines published by HHS. The Organization's Period 1 portal submission overstated expenses by $5,703,280, that were included within the Organization's PPP loan forgiveness application. These expenses should not have been included within the Period 1 submission. Due to the Organization having excess allowable health care expenses and lost revenue reported in the portal submission that could have been utilized to support the retention of the PRF funds, the Organization still had qualified expenditures to recognize all PRF payments received in Period 1. Cause and Effect The review process surrounding the expenses reported was not sufficient to ensure that the expenses were accurately reported. As a result, the report submitted was inaccurate. Recommendation We recommend the Organization enhance controls, including additional levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan The Organization accepts the finding and has implemented additional layers of review regarding expense submission to ensure the reports are submitted within the established guidelines. The submission was prepared by prior management that is no longer at the organization during a period of transition from the acquisition by Beacon. Subsequent reporting was performed for TRH by Beacon management after this initial submission and subsequent audits were performed with all findings resolved. As stated above, the Organization had sufficient additional expenditures and lost revenue from the COVID 19 pandemic and there are no resulting PRF recognition issues.