Audit 308439

Program Name/CFDA Title: Provider Relief Fund Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Reporting Condition: The Organization did not meet its requirements in the reporting the use of its Provider Relief Funds by certain amounts as they related to preventing, preparing for, and responding to coronavirus. Criteria: The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. There is also a responsibility on recipients of the Provider Relief Funds to report on various distributions received how the funds were utilized, maintain appropriate records, and complete online attestation forms with accuracy. Context: During the audit, it was determined that two of entities which received Provider Relief Funds and American Rescue Plan Act funds had items which resulted in alternative amounts needing to be reported for lost revenues in the HRSA online portals; however, there was alternative support which covered the full amount of the funding received. In review of the submitted information to HRSA, Androscoggin Valley Hospital, Inc. (the “Hospital”) included retail pharmacy revenue from its participation with contracted pharmacies in the 340B Drug Discount program in the lost revenue calculations. The guidance on allowable lost revenue from HRSA as published on the HRSA website notes that retail pharmacy and retail sales should not be included in the lost patient service revenue calculations for healthcare providers. In review, the Hospital had other lost revenue from its general hospital patient service revenue that would have more than covered the remaining use of the Provider Relief Funds and American Rescue Plan Rural Distributions received; however, its portal reporting should be updated to remove the retail pharmacy revenue.   Also, in review of the submitted information to HRSA, North Country Home Health & Hospice Agency, Inc. (the “Agency”) did not have the support on file which matched the online portal submission for lost revenue. During the audit, this was recreated through assistance of the agency in providing quarterly financial information during the periods of lost revenue; however, in review of the calculations there was an immaterial difference in reporting of lost revenue which although would not have caused a repayment of any Provider Relief Funds or American Rescue Plan Act Rural Distributions, it would have changed the amounts of lost revenue reported in some of the applicable quarters. Some of the lack of maintaining of records may have also been caused due to significant turnover in personnel and responsibilities at the Agency during this time period. Cause: Management oversight. Effect: The Organization is not in compliance with federal regulations and guidelines surrounding the reporting of use of the Provider Relief Funds. Recommendation: We recommend that management update its portal reporting with HRSA and notify the agency that an update should have been made to its required reporting to show conformity with reporting requirements. View of Responsible Officials: Management will work to update past reporting to HRSA, along with maintaining required supporting documentation, as well as track any required adjustments needed for future Provider Relief Fund and American Rescue Plan Rural Distributions distributions in case there is any additional required reporting in the future.

Program Name/CFDA Title: Provider Relief Fund Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Reporting Condition: The Organization did not meet its requirements in the reporting the use of its Provider Relief Funds by certain amounts as they related to preventing, preparing for, and responding to coronavirus. Criteria: The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. There is also a responsibility on recipients of the Provider Relief Funds to report on various distributions received how the funds were utilized, maintain appropriate records, and complete online attestation forms with accuracy. Context: During the audit, it was determined that two of entities which received Provider Relief Funds and American Rescue Plan Act funds had items which resulted in alternative amounts needing to be reported for lost revenues in the HRSA online portals; however, there was alternative support which covered the full amount of the funding received. In review of the submitted information to HRSA, Androscoggin Valley Hospital, Inc. (the “Hospital”) included retail pharmacy revenue from its participation with contracted pharmacies in the 340B Drug Discount program in the lost revenue calculations. The guidance on allowable lost revenue from HRSA as published on the HRSA website notes that retail pharmacy and retail sales should not be included in the lost patient service revenue calculations for healthcare providers. In review, the Hospital had other lost revenue from its general hospital patient service revenue that would have more than covered the remaining use of the Provider Relief Funds and American Rescue Plan Rural Distributions received; however, its portal reporting should be updated to remove the retail pharmacy revenue.   Also, in review of the submitted information to HRSA, North Country Home Health & Hospice Agency, Inc. (the “Agency”) did not have the support on file which matched the online portal submission for lost revenue. During the audit, this was recreated through assistance of the agency in providing quarterly financial information during the periods of lost revenue; however, in review of the calculations there was an immaterial difference in reporting of lost revenue which although would not have caused a repayment of any Provider Relief Funds or American Rescue Plan Act Rural Distributions, it would have changed the amounts of lost revenue reported in some of the applicable quarters. Some of the lack of maintaining of records may have also been caused due to significant turnover in personnel and responsibilities at the Agency during this time period. Cause: Management oversight. Effect: The Organization is not in compliance with federal regulations and guidelines surrounding the reporting of use of the Provider Relief Funds. Recommendation: We recommend that management update its portal reporting with HRSA and notify the agency that an update should have been made to its required reporting to show conformity with reporting requirements. View of Responsible Officials: Management will work to update past reporting to HRSA, along with maintaining required supporting documentation, as well as track any required adjustments needed for future Provider Relief Fund and American Rescue Plan Rural Distributions distributions in case there is any additional required reporting in the future.