Audit 310398

FY End
2023-09-30
Total Expended
$34.90M
Findings
2
Programs
5
Organization: Southcoast Health System, Inc. (MA)
Year: 2023 Accepted: 2024-06-27

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
403242 2023-001 - - N
979684 2023-001 - - N

Contacts

Name Title Type
KDU9TMGM2TH6 Ross Replogle Auditee
5089732970 Kevin McGraw Auditor
No contacts on file

Notes to SEFA

Title: U.S. Department of Health and Human Services COVID-19 Provider Relief Funds Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Southcoast Health System, Inc. and its subsidiaries (the System) under programs of the federal government for the year ended September 30, 2023. The information in this Schedule is presented 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 (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the financial position, results of operations and changes in net assets or cash flows of the System. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Amounts reported on the Schedule include replacement of lost revenue and eligible expenditures. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented when available. De Minimis Rate Used: N Rate Explanation: For purposes of charging indirect costs to federal awards, the System has not elected to use the 10 percent de minimis cost rate as permitted by §200.414 of the Uniform Guidance. The Schedule includes grant activity related to the U.S. Department of Health and Human Services (HHS) COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Distribution Assistance Listing Number 93.498. As required based on guidance in the 2023 OMB Compliance Supplement, the Schedule includes all Period 5 funds received between January 1, 2022 and June 30, 2022 and expended by June 30, 2023 as reported to HRSA via the PRF Reporting Portal. The System did not receive any Period 4 funds. Given the timing covered by Period 5 funds, these expenses and lost revenues were reflected in the System’s fiscal year 2022 consolidated financial statements. Additionally, lost revenue does not represent an expenditure in the System’s consolidated financial statements and thus is a reconciling item between the federal expenses in the System's consolidated financial statements and the amount included on the Schedule.
Title: Federal Emergency Management Agency (FEMA) Public Assistance Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Southcoast Health System, Inc. and its subsidiaries (the System) under programs of the federal government for the year ended September 30, 2023. The information in this Schedule is presented 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 (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the financial position, results of operations and changes in net assets or cash flows of the System. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Amounts reported on the Schedule include replacement of lost revenue and eligible expenditures. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented when available. De Minimis Rate Used: N Rate Explanation: For purposes of charging indirect costs to federal awards, the System has not elected to use the 10 percent de minimis cost rate as permitted by §200.414 of the Uniform Guidance. The System applied for reimbursement of certain expenses related to the COVID-19 pandemic under Assistance Listing Number 97.036, FEMA Public Assistance through the Commonwealth of Massachusetts. Expenditures are reflected in the Schedule in the year in which a project application is obligated. The Schedule thus includes $27,469,425 of expenditures incurred in fiscal years 2021 and 2022, which were obligated in fiscal year 2023 and represents a reconciling item between the federal expenses in the System’s financial statements and the amount included on the Schedule.

Finding Details

2023-001 Congressional Directives Principal Investigator Cluster: Not applicable Grantor: U.S. Department of Health and Human Services Award Names: Congressional Directives Award Year: August 1, 2022 – July 31, 2025 Award Number: 1 CE1HS46621‐01‐00 Assistance Listing Number: 93.493 Pass-through entity: Not applicable Criteria The recipient is required to notify the Grants Management Officer (GMO) in writing if the Principal Investigator (PI)/Program or Project Director (PD) or key personnel specifically named in the Notice of Award (NoA) will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of award (for example, a proposed change from 40 percent effort to 30 percent or less effort). The HHS Operating Divisions (OPDIV) must approve any alternate arrangement proposed by the recipient, including any replacement of the PI/PD or key personnel named in the NoA. Condition We noted the PI specifically named in the NoA resigned from the System in February 2023. Management identified a replacement of the PI to oversee the grant; however, management did not notify the GMO in writing that the PI would withdraw from the project and did not obtain approval from the OPDIV regarding the replacement. Cause Management did not have a control in place to notify the GMO and request approval from OPDIV upon the PI withdrawal from the grant. Effect The System was not in compliance with the requirement to notify the GMO and OPDIV of the change in the PI role. Questioned Costs None identified. Recommendation We recommend that management communicate with their GMO and OPDIV, as applicable, regarding this matter and implement a control that monitors the PIs assigned to each grant to ensure that they are notifying the GMO of any changes in status and obtaining approval from the OPDIV in a timely manner. Management’s View and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2023-001 Congressional Directives Principal Investigator Cluster: Not applicable Grantor: U.S. Department of Health and Human Services Award Names: Congressional Directives Award Year: August 1, 2022 – July 31, 2025 Award Number: 1 CE1HS46621‐01‐00 Assistance Listing Number: 93.493 Pass-through entity: Not applicable Criteria The recipient is required to notify the Grants Management Officer (GMO) in writing if the Principal Investigator (PI)/Program or Project Director (PD) or key personnel specifically named in the Notice of Award (NoA) will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of award (for example, a proposed change from 40 percent effort to 30 percent or less effort). The HHS Operating Divisions (OPDIV) must approve any alternate arrangement proposed by the recipient, including any replacement of the PI/PD or key personnel named in the NoA. Condition We noted the PI specifically named in the NoA resigned from the System in February 2023. Management identified a replacement of the PI to oversee the grant; however, management did not notify the GMO in writing that the PI would withdraw from the project and did not obtain approval from the OPDIV regarding the replacement. Cause Management did not have a control in place to notify the GMO and request approval from OPDIV upon the PI withdrawal from the grant. Effect The System was not in compliance with the requirement to notify the GMO and OPDIV of the change in the PI role. Questioned Costs None identified. Recommendation We recommend that management communicate with their GMO and OPDIV, as applicable, regarding this matter and implement a control that monitors the PIs assigned to each grant to ensure that they are notifying the GMO of any changes in status and obtaining approval from the OPDIV in a timely manner. Management’s View and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.