FAC Explorer

Audit 309562

FY End
2023-12-31
Total Expended
$5.01M
Findings
4
Programs
17
Organization: Saint Luke's Health System, INC (MO)
Year: 2023 Accepted: 2024-06-21
Auditor: Ernst & Young LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
401509 2023-001 Significant Deficiency - N
401510 2023-001 Significant Deficiency - N
977951 2023-001 Significant Deficiency - N
977952 2023-001 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $558,251 - 0
93.350 National Center for Advancing Translational Sciences $149,986 Yes 0
93.838 Lung Diseases Research $78,408 Yes 0
10.555 National School Lunch Program $77,827 - 0
93.855 Allergy and Infectious Diseases Research $65,300 Yes 0
93.839 Blood Diseases and Resources Research $54,061 Yes 0
93.301 Small Rural Hospital Improvement Grant Program $44,848 - 0
93.866 Aging Research $37,794 Yes 0
93.837 Cardiovascular Diseases Research $31,737 Yes 0
10.553 School Breakfast Program $29,763 - 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $16,966 Yes 1
93.945 Assistance Programs for Chronic Disease Prevention and Control $14,432 - 0
97.036 Covid-19 Disaster Grants-Public Assistance (presidentially Declared Disasters) $11,040 - 0
93.226 Research on Healthcare Costs, Quality, and Outcomes $7,014 Yes 0
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $7,000 - 0
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $4,505 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $3,586 Yes 0

Contacts

Name Title Type
ZZWNRV2LKDN3 Rebecca Peck Auditee
8169368713 Maureen Wood Auditor
No contacts on file

Notes to SEFA

Title: Significant Accounting Policies Used in Preparing the Schedule of Expenditures of Federal Awards. Accounting Policies: All federal awards of Saint Luke’s Health System, Inc. and subsidiaries (collectively, the System) are included in the Schedule of Expenditures of Federal Awards (Schedule). The Schedule, by grantor agency, presents the program expenditures for all federal financial assistance programs of the System that had expenditures in 2023. For purposes of this report, federal awards are those received directly from a federal agency and those awards received from other agencies, the original source of which was a federal agency. The expenditures reported in the Schedule have been presented on the accrual basis of accounting in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Accordingly, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The System did not use the 10% de minimis cost rate allowed by the Uniform Guidance. All federal awards of Saint Luke’s Health System, Inc. and subsidiaries (collectively, the System) are included in the Schedule of Expenditures of Federal Awards (Schedule). The Schedule, by grantor agency, presents the program expenditures for all federal financial assistance programs of the System that had expenditures in 2023. For purposes of this report, federal awards are those received directly from a federal agency and those awards received from other agencies, the original source of which was a federal agency. The expenditures reported in the Schedule have been presented on the accrual basis of accounting in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Accordingly, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the consolidated financial statements.
Title: 10% De Minimi Cost Rate Accounting Policies: All federal awards of Saint Luke’s Health System, Inc. and subsidiaries (collectively, the System) are included in the Schedule of Expenditures of Federal Awards (Schedule). The Schedule, by grantor agency, presents the program expenditures for all federal financial assistance programs of the System that had expenditures in 2023. For purposes of this report, federal awards are those received directly from a federal agency and those awards received from other agencies, the original source of which was a federal agency. The expenditures reported in the Schedule have been presented on the accrual basis of accounting in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Accordingly, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The System did not use the 10% de minimis cost rate allowed by the Uniform Guidance. The System did not use the 10% de minimis cost rate allowed by the Uniform Guidance.
Title: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (Assistance Listing No. 93.498) Accounting Policies: All federal awards of Saint Luke’s Health System, Inc. and subsidiaries (collectively, the System) are included in the Schedule of Expenditures of Federal Awards (Schedule). The Schedule, by grantor agency, presents the program expenditures for all federal financial assistance programs of the System that had expenditures in 2023. For purposes of this report, federal awards are those received directly from a federal agency and those awards received from other agencies, the original source of which was a federal agency. The expenditures reported in the Schedule have been presented on the accrual basis of accounting in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Accordingly, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The System did not use the 10% de minimis cost rate allowed by the Uniform Guidance. The Schedule includes $558,251 received from the Department of Health and Human Services (HHS) between January 1, 2022 and June 30, 2022, under the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) program of Assistance Listing No. 93.498. These amounts are reported as Period 5 in the HHS PRF Reporting Portal. These amounts were recognized as other operating revenue in the System’s consolidated financial statements in the accompanying consolidated statements of operations and changes in net assets for the years ended December 31, 2023 and 2022. The amount presented on the Schedule for PRF is for the year ended December 31, 2023. The amount presented reconciles to the PRF information reported to HHS as follows: See the Notes to the SEFAfor chart/table.
Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Accounting Policies: All federal awards of Saint Luke’s Health System, Inc. and subsidiaries (collectively, the System) are included in the Schedule of Expenditures of Federal Awards (Schedule). The Schedule, by grantor agency, presents the program expenditures for all federal financial assistance programs of the System that had expenditures in 2023. For purposes of this report, federal awards are those received directly from a federal agency and those awards received from other agencies, the original source of which was a federal agency. The expenditures reported in the Schedule have been presented on the accrual basis of accounting in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Accordingly, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The System did not use the 10% de minimis cost rate allowed by the Uniform Guidance. The System incurred eligible disaster expenditures related to the COVID-19 pandemic. After a presidentially declared disaster, the Federal Emergency Management Agency (FEMA) provides Disaster Grants – Public Assistance (Assistance Listing No. 97.036) to reimburse eligible costs. For the year ended December 31, 2023, FEMA obligated $2,793,334 of eligible expenditures that were incurred in prior years. This amount has been included in the Schedule.

Finding Details

Finding 2023-001
Finding 2023-001 – Special Tests and Provisions – Key Personnel Information of the federal program: Research and Development (R&D) Cluster Federal Grantor: U.S. Department of Health and Human Services Pass-Through Grantor: Oregon Health & Science University Assistance Listing No.: 93.847 Pass-Through Award Number: 1020881_STLUKES Pass-Through Award Period: 09/03/2021-12/31/2023 Pass-Through Grantor: University of Southern California Assistance Listing No.: 93.837 Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Pass-Through Award Period: 03/22/2019-02/29/2024 Pass-Through Grantor: The Curators of the University of Missouri on Behalf of University of Missouri at Kansas City Assistance Listing No.: 93.103 Pass-Through Award Numbers: 00119058/00079685 Pass-Through Award Period: 09/30/22-09/29/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the 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 Uniform Guidance 2 CRF Subpart D section 200.308(c) states the following: “For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (2) Change in a key person specified in the application or the Federal award; (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.” Condition: Saint Luke’s Health System, Inc. (the System) did not obtain or timely obtain prior approval from Federal awarding agencies for changes in effort of key personnel specifically named in the federal award. Cause: Management did not have suitably designed internal controls to monitor changes in effort throughout the year and to ensure the required approval from Federal awarding agencies was obtained on a timely basis. Effect or potential effect: The System is not in compliance with 2 CRF Subpart D section 200.308(c) and the terms and conditions of the federal program regarding key personnel. Questioned costs: $25,045 was calculated as the salaries, benefits, and indirect costs expensed to the federal award for the months where the key personnel’s change in effort was more than 25% for the key personnel in question and not reported to the federal award agency. Assistance Listing No. 93.837 Pass-Through Grantor: University of Southern California Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Salaries and Benefits – $17,638 Indirect Costs – $7,407 Total – $25,045 Context: The required approval from the Federal awarding agency was not obtained or not obtained timely for a total of six key personnel (17%) out of a population of 35 key personnel specifically named in the federal awards as key personnel for whom a prior approval is required for a significant change in effort. Out of the total of six changes in effort of key personnel that were more than 25% lower than the committed effort per the agreement, there were four (11%) changes where the required approval was not obtained and there were two (6%) changes where the required approval was not obtained timely. Total R&D Cluster program expenditures were $1,482,128 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Saint Luke’s Health System should implement an internal control over the monitoring of changes in effort of key personnel to enable compliance with prior approval requirements of the federal program. Views of responsible officials: Quarterly reviews of key personnel effort were instituted in December 2023 to allow for timely identification and communication of potential changes in key personnel or significant reductions of effort.
Finding 2023-001
Finding 2023-001 – Special Tests and Provisions – Key Personnel Information of the federal program: Research and Development (R&D) Cluster Federal Grantor: U.S. Department of Health and Human Services Pass-Through Grantor: Oregon Health & Science University Assistance Listing No.: 93.847 Pass-Through Award Number: 1020881_STLUKES Pass-Through Award Period: 09/03/2021-12/31/2023 Pass-Through Grantor: University of Southern California Assistance Listing No.: 93.837 Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Pass-Through Award Period: 03/22/2019-02/29/2024 Pass-Through Grantor: The Curators of the University of Missouri on Behalf of University of Missouri at Kansas City Assistance Listing No.: 93.103 Pass-Through Award Numbers: 00119058/00079685 Pass-Through Award Period: 09/30/22-09/29/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the 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 Uniform Guidance 2 CRF Subpart D section 200.308(c) states the following: “For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (2) Change in a key person specified in the application or the Federal award; (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.” Condition: Saint Luke’s Health System, Inc. (the System) did not obtain or timely obtain prior approval from Federal awarding agencies for changes in effort of key personnel specifically named in the federal award. Cause: Management did not have suitably designed internal controls to monitor changes in effort throughout the year and to ensure the required approval from Federal awarding agencies was obtained on a timely basis. Effect or potential effect: The System is not in compliance with 2 CRF Subpart D section 200.308(c) and the terms and conditions of the federal program regarding key personnel. Questioned costs: $25,045 was calculated as the salaries, benefits, and indirect costs expensed to the federal award for the months where the key personnel’s change in effort was more than 25% for the key personnel in question and not reported to the federal award agency. Assistance Listing No. 93.837 Pass-Through Grantor: University of Southern California Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Salaries and Benefits – $17,638 Indirect Costs – $7,407 Total – $25,045 Context: The required approval from the Federal awarding agency was not obtained or not obtained timely for a total of six key personnel (17%) out of a population of 35 key personnel specifically named in the federal awards as key personnel for whom a prior approval is required for a significant change in effort. Out of the total of six changes in effort of key personnel that were more than 25% lower than the committed effort per the agreement, there were four (11%) changes where the required approval was not obtained and there were two (6%) changes where the required approval was not obtained timely. Total R&D Cluster program expenditures were $1,482,128 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Saint Luke’s Health System should implement an internal control over the monitoring of changes in effort of key personnel to enable compliance with prior approval requirements of the federal program. Views of responsible officials: Quarterly reviews of key personnel effort were instituted in December 2023 to allow for timely identification and communication of potential changes in key personnel or significant reductions of effort.
Finding 2023-001
Finding 2023-001 – Special Tests and Provisions – Key Personnel Information of the federal program: Research and Development (R&D) Cluster Federal Grantor: U.S. Department of Health and Human Services Pass-Through Grantor: Oregon Health & Science University Assistance Listing No.: 93.847 Pass-Through Award Number: 1020881_STLUKES Pass-Through Award Period: 09/03/2021-12/31/2023 Pass-Through Grantor: University of Southern California Assistance Listing No.: 93.837 Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Pass-Through Award Period: 03/22/2019-02/29/2024 Pass-Through Grantor: The Curators of the University of Missouri on Behalf of University of Missouri at Kansas City Assistance Listing No.: 93.103 Pass-Through Award Numbers: 00119058/00079685 Pass-Through Award Period: 09/30/22-09/29/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the 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 Uniform Guidance 2 CRF Subpart D section 200.308(c) states the following: “For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (2) Change in a key person specified in the application or the Federal award; (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.” Condition: Saint Luke’s Health System, Inc. (the System) did not obtain or timely obtain prior approval from Federal awarding agencies for changes in effort of key personnel specifically named in the federal award. Cause: Management did not have suitably designed internal controls to monitor changes in effort throughout the year and to ensure the required approval from Federal awarding agencies was obtained on a timely basis. Effect or potential effect: The System is not in compliance with 2 CRF Subpart D section 200.308(c) and the terms and conditions of the federal program regarding key personnel. Questioned costs: $25,045 was calculated as the salaries, benefits, and indirect costs expensed to the federal award for the months where the key personnel’s change in effort was more than 25% for the key personnel in question and not reported to the federal award agency. Assistance Listing No. 93.837 Pass-Through Grantor: University of Southern California Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Salaries and Benefits – $17,638 Indirect Costs – $7,407 Total – $25,045 Context: The required approval from the Federal awarding agency was not obtained or not obtained timely for a total of six key personnel (17%) out of a population of 35 key personnel specifically named in the federal awards as key personnel for whom a prior approval is required for a significant change in effort. Out of the total of six changes in effort of key personnel that were more than 25% lower than the committed effort per the agreement, there were four (11%) changes where the required approval was not obtained and there were two (6%) changes where the required approval was not obtained timely. Total R&D Cluster program expenditures were $1,482,128 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Saint Luke’s Health System should implement an internal control over the monitoring of changes in effort of key personnel to enable compliance with prior approval requirements of the federal program. Views of responsible officials: Quarterly reviews of key personnel effort were instituted in December 2023 to allow for timely identification and communication of potential changes in key personnel or significant reductions of effort.
Finding 2023-001
Finding 2023-001 – Special Tests and Provisions – Key Personnel Information of the federal program: Research and Development (R&D) Cluster Federal Grantor: U.S. Department of Health and Human Services Pass-Through Grantor: Oregon Health & Science University Assistance Listing No.: 93.847 Pass-Through Award Number: 1020881_STLUKES Pass-Through Award Period: 09/03/2021-12/31/2023 Pass-Through Grantor: University of Southern California Assistance Listing No.: 93.837 Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Pass-Through Award Period: 03/22/2019-02/29/2024 Pass-Through Grantor: The Curators of the University of Missouri on Behalf of University of Missouri at Kansas City Assistance Listing No.: 93.103 Pass-Through Award Numbers: 00119058/00079685 Pass-Through Award Period: 09/30/22-09/29/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the 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 Uniform Guidance 2 CRF Subpart D section 200.308(c) states the following: “For non-construction Federal awards, recipients must request prior approvals from Federal awarding agencies for the following program or budget-related reasons: (2) Change in a key person specified in the application or the Federal award; (3) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.” Condition: Saint Luke’s Health System, Inc. (the System) did not obtain or timely obtain prior approval from Federal awarding agencies for changes in effort of key personnel specifically named in the federal award. Cause: Management did not have suitably designed internal controls to monitor changes in effort throughout the year and to ensure the required approval from Federal awarding agencies was obtained on a timely basis. Effect or potential effect: The System is not in compliance with 2 CRF Subpart D section 200.308(c) and the terms and conditions of the federal program regarding key personnel. Questioned costs: $25,045 was calculated as the salaries, benefits, and indirect costs expensed to the federal award for the months where the key personnel’s change in effort was more than 25% for the key personnel in question and not reported to the federal award agency. Assistance Listing No. 93.837 Pass-Through Grantor: University of Southern California Pass-Through Award Numbers: 117726140/SCON-00003287; 117726140/SCON-00005033 Salaries and Benefits – $17,638 Indirect Costs – $7,407 Total – $25,045 Context: The required approval from the Federal awarding agency was not obtained or not obtained timely for a total of six key personnel (17%) out of a population of 35 key personnel specifically named in the federal awards as key personnel for whom a prior approval is required for a significant change in effort. Out of the total of six changes in effort of key personnel that were more than 25% lower than the committed effort per the agreement, there were four (11%) changes where the required approval was not obtained and there were two (6%) changes where the required approval was not obtained timely. Total R&D Cluster program expenditures were $1,482,128 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Saint Luke’s Health System should implement an internal control over the monitoring of changes in effort of key personnel to enable compliance with prior approval requirements of the federal program. Views of responsible officials: Quarterly reviews of key personnel effort were instituted in December 2023 to allow for timely identification and communication of potential changes in key personnel or significant reductions of effort.