Audit 310766

FY End
2023-09-30
Total Expended
$29.98M
Findings
4
Programs
24
Organization: Nuvance Health and Subsidiaries (CT)
Year: 2023 Accepted: 2024-06-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
403892 2023-001 Significant Deficiency - I
403893 2023-001 Significant Deficiency - I
980334 2023-001 Significant Deficiency - I
980335 2023-001 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $17.05M Yes 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4.39M - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.09M Yes 0
32.005 Universal Service Fund - Rural Health Care $681,654 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $505,940 Yes 1
93.959 Block Grants for Prevention and Treatment of Substance Abuse $137,943 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $126,159 - 0
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $119,868 - 0
93.889 National Bioterrorism Hospital Preparedness Program $118,500 - 0
93.394 Cancer Detection and Diagnosis Research $87,671 - 0
93.650 Accountable Health Communities $74,432 - 0
93.268 Immunization Cooperative Agreements $52,783 - 0
93.865 Child Health and Human Development Extramural Research $49,966 - 0
93.399 Cancer Control $33,300 - 0
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $17,760 - 0
93.395 Cancer Treatment Research $12,100 - 0
16.575 Crime Victim Assistance $11,338 - 0
93.914 Hiv Emergency Relief Project Grants $11,220 - 0
93.493 Congressional Directives $9,362 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $5,476 - 0
93.958 Block Grants for Community Mental Health Services $4,909 - 0
93.800 Organized Approaches to Increase Colorectal Cancer Screening $4,782 - 0
20.616 National Priority Safety Programs $4,566 - 0
93.866 Aging Research $2,570 - 0

Contacts

Name Title Type
VZJVB8RFBJR8 Devin Murphy Auditee
4019323469 Amie Allegro Auditor
No contacts on file

Notes to SEFA

Title: 3. Consolidated Reporting Accounting Policies: 1. Background, Summary of Significant Accounting Policies and Basis of Presentation Financial Assistance Various departments and agencies of the federal government have provided financial assistance to Nuvance Health and Subsidiaries (the “System”) through grants and other awards in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Those financial assistance programs provide funding for several programs. Summary of Significant Accounting Policies The accounting policies of the System conform to accounting principles generally accepted in the United States of America as applicable to not-for-profit health care entities. The following is a summary of the more significant policies relating to the aforementioned grant programs. Basis of Presentation The consolidated financial statements contained in the System’s annual audit report are prepared on the accrual basis of accounting. Refer to the notes to the consolidated financial statements for a summary of the significant accounting policies. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the System and is presented on the accrual basis of accounting. The information in the 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 (the Uniform Guidance). In accordance with these requirements, certain grants are not dependent on expenditure activity, and accordingly, are considered to be expended in the fiscal year of receipt; the grant program receipts of such awards are reflected in the expenditures columns of the Schedule. Additionally, in accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Notes 5, 6 and 7). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the System’s consolidated financial statements.   Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX and 45 CFR Part 74 Appendix E, as applicable. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election. The System uses a combination of a federally negotiated rate, award-specific rates, or the 10% de minimis rate by entity and program. The federal award activity of the entities noted below is included in the accompanying Schedule for the year ended September 30, 2023: See Notes to SEFA for chart/table.
Title: 4. Non-Cash Assistance Accounting Policies: 1. Background, Summary of Significant Accounting Policies and Basis of Presentation Financial Assistance Various departments and agencies of the federal government have provided financial assistance to Nuvance Health and Subsidiaries (the “System”) through grants and other awards in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Those financial assistance programs provide funding for several programs. Summary of Significant Accounting Policies The accounting policies of the System conform to accounting principles generally accepted in the United States of America as applicable to not-for-profit health care entities. The following is a summary of the more significant policies relating to the aforementioned grant programs. Basis of Presentation The consolidated financial statements contained in the System’s annual audit report are prepared on the accrual basis of accounting. Refer to the notes to the consolidated financial statements for a summary of the significant accounting policies. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the System and is presented on the accrual basis of accounting. The information in the 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 (the Uniform Guidance). In accordance with these requirements, certain grants are not dependent on expenditure activity, and accordingly, are considered to be expended in the fiscal year of receipt; the grant program receipts of such awards are reflected in the expenditures columns of the Schedule. Additionally, in accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Notes 5, 6 and 7). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the System’s consolidated financial statements.   Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX and 45 CFR Part 74 Appendix E, as applicable. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election. The System uses a combination of a federally negotiated rate, award-specific rates, or the 10% de minimis rate by entity and program. During the year ended September 30, 2023, the U.S. Department of Health and Human Services issued $52,783 in federally funded vaccines to the System through the Immunization Cooperative Agreements program (Assistance Listing No. (ALN) 93.268). This non-cash assistance, which was passed through the State of Connecticut Department of Public Health, is included in the accompanying Schedule.
Title: 5. Universal Service Fund – Rural Health Care Accounting Policies: 1. Background, Summary of Significant Accounting Policies and Basis of Presentation Financial Assistance Various departments and agencies of the federal government have provided financial assistance to Nuvance Health and Subsidiaries (the “System”) through grants and other awards in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Those financial assistance programs provide funding for several programs. Summary of Significant Accounting Policies The accounting policies of the System conform to accounting principles generally accepted in the United States of America as applicable to not-for-profit health care entities. The following is a summary of the more significant policies relating to the aforementioned grant programs. Basis of Presentation The consolidated financial statements contained in the System’s annual audit report are prepared on the accrual basis of accounting. Refer to the notes to the consolidated financial statements for a summary of the significant accounting policies. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the System and is presented on the accrual basis of accounting. The information in the 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 (the Uniform Guidance). In accordance with these requirements, certain grants are not dependent on expenditure activity, and accordingly, are considered to be expended in the fiscal year of receipt; the grant program receipts of such awards are reflected in the expenditures columns of the Schedule. Additionally, in accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Notes 5, 6 and 7). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the System’s consolidated financial statements.   Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX and 45 CFR Part 74 Appendix E, as applicable. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election. The System uses a combination of a federally negotiated rate, award-specific rates, or the 10% de minimis rate by entity and program. The System received funding from the Federal Communications Commission (FCC) through the Universal Service Fund – Rural Health Care (ALN 32.005) to reimburse eligible costs. In fiscal year 2023, the FCC approved $681,654 of eligible expenditures, inclusive of $173,976 of expenditures that were incurred in prior fiscal years. This amount has been included in the accompanying Schedule for the year ended September 30, 2023 in accordance with the guidance specific to ALN 32.005.
Title: 6. COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Accounting Policies: 1. Background, Summary of Significant Accounting Policies and Basis of Presentation Financial Assistance Various departments and agencies of the federal government have provided financial assistance to Nuvance Health and Subsidiaries (the “System”) through grants and other awards in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Those financial assistance programs provide funding for several programs. Summary of Significant Accounting Policies The accounting policies of the System conform to accounting principles generally accepted in the United States of America as applicable to not-for-profit health care entities. The following is a summary of the more significant policies relating to the aforementioned grant programs. Basis of Presentation The consolidated financial statements contained in the System’s annual audit report are prepared on the accrual basis of accounting. Refer to the notes to the consolidated financial statements for a summary of the significant accounting policies. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the System and is presented on the accrual basis of accounting. The information in the 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 (the Uniform Guidance). In accordance with these requirements, certain grants are not dependent on expenditure activity, and accordingly, are considered to be expended in the fiscal year of receipt; the grant program receipts of such awards are reflected in the expenditures columns of the Schedule. Additionally, in accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Notes 5, 6 and 7). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the System’s consolidated financial statements.   Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX and 45 CFR Part 74 Appendix E, as applicable. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election. The System uses a combination of a federally negotiated rate, award-specific rates, or the 10% de minimis rate by entity and program. 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 (Presidentially Declared Disasters) (ALN 97.036) to reimburse eligible costs. In fiscal year 2023, FEMA approved $9,121,718 of eligible expenditures that were incurred in prior fiscal years. This amount has been included in the accompanying Schedule for the year ended September 30, 2023 in accordance with the guidance specific to ALN 97.036.
Title: 7. COVID-19 – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Accounting Policies: 1. Background, Summary of Significant Accounting Policies and Basis of Presentation Financial Assistance Various departments and agencies of the federal government have provided financial assistance to Nuvance Health and Subsidiaries (the “System”) through grants and other awards in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). Those financial assistance programs provide funding for several programs. Summary of Significant Accounting Policies The accounting policies of the System conform to accounting principles generally accepted in the United States of America as applicable to not-for-profit health care entities. The following is a summary of the more significant policies relating to the aforementioned grant programs. Basis of Presentation The consolidated financial statements contained in the System’s annual audit report are prepared on the accrual basis of accounting. Refer to the notes to the consolidated financial statements for a summary of the significant accounting policies. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of the System and is presented on the accrual basis of accounting. The information in the 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 (the Uniform Guidance). In accordance with these requirements, certain grants are not dependent on expenditure activity, and accordingly, are considered to be expended in the fiscal year of receipt; the grant program receipts of such awards are reflected in the expenditures columns of the Schedule. Additionally, in accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Notes 5, 6 and 7). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the System’s consolidated financial statements.   Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX and 45 CFR Part 74 Appendix E, as applicable. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Both Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election. The System uses a combination of a federally negotiated rate, award-specific rates, or the 10% de minimis rate by entity and program. In accordance with the requirements specific to ALN 93.498, COVID-19 – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, the amount presented on the accompanying Schedule for the year ended September 30, 2023 for ALN 93.498 relates to (i) activity from the period January 1, 2020 through June 30, 2023 for (ii) Provider Relief Fund (PRF) payments received from July 1, 2021 through June 30, 2022. This activity period and payment receipt period and the resulting amount presented reconciles to the PRF information previously reported to the Health Resources and Services Administration (HRSA) for PRF Reporting Periods 4 and 5 as follows: See Notes to SEFA for Chart/table. The expenses attributable to Coronavirus Disease 2019 (COVID-19) and lost revenues incurred by the System during the period of availability for PRF Reporting Period 4 (January 1, 2020 through December 31, 2022) and PRF Reporting Period 5 (January 1, 2020 through June 30, 2023) are in excess of the general and targeted distributions received in PRF Reporting Periods 1 through 3 (which addressed payments received during April 10, 2020 to June 30, 2021, and previously reported on the schedule of expenditures of federal awards for the years ended September 30, 2022 and 2021) and distributions received from July 1, 2021 through June 30, 2022 and, therefore, the amounts presented in the table above and on the accompanying Schedule are limited to the amount of such distributions.

Finding Details

Finding Reference: 2023-001 – I. Procurement, Suspension and Debarment Information on the Federal Program: Grantor: Department of the Treasury Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Criteria or Specific Requirement: For compliance requirement I.1 Procurement, Nuvance Health and Subsidiaries (the “System”) must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. The System may also use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: As part of our testing over the operating effectiveness of internal controls over the Procurement compliance requirement, we noted that the System did not have a procurement policy that conforms to all applicable federal laws, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the federal funds related to the program. Cause: The System did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving federal funds related to the program. Effect or Potential Effect: Purchasing of goods and/or services with program funds may not be in compliance with the Uniform Guidance. Questioned Costs: Not applicable. Context: The System’s internal procurement policy has not been reviewed to incorporate all of the required provisions within 2 CFR 200.318 through 200.327. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: The System should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials: Management concurs with this finding and is currently drafting a procurement policy to incorporate the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds.
Finding Reference: 2023-001 – I. Procurement, Suspension and Debarment Information on the Federal Program: Grantor: Department of the Treasury Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Criteria or Specific Requirement: For compliance requirement I.1 Procurement, Nuvance Health and Subsidiaries (the “System”) must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. The System may also use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: As part of our testing over the operating effectiveness of internal controls over the Procurement compliance requirement, we noted that the System did not have a procurement policy that conforms to all applicable federal laws, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the federal funds related to the program. Cause: The System did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving federal funds related to the program. Effect or Potential Effect: Purchasing of goods and/or services with program funds may not be in compliance with the Uniform Guidance. Questioned Costs: Not applicable. Context: The System’s internal procurement policy has not been reviewed to incorporate all of the required provisions within 2 CFR 200.318 through 200.327. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: The System should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials: Management concurs with this finding and is currently drafting a procurement policy to incorporate the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds.
Finding Reference: 2023-001 – I. Procurement, Suspension and Debarment Information on the Federal Program: Grantor: Department of the Treasury Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Criteria or Specific Requirement: For compliance requirement I.1 Procurement, Nuvance Health and Subsidiaries (the “System”) must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. The System may also use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: As part of our testing over the operating effectiveness of internal controls over the Procurement compliance requirement, we noted that the System did not have a procurement policy that conforms to all applicable federal laws, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the federal funds related to the program. Cause: The System did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving federal funds related to the program. Effect or Potential Effect: Purchasing of goods and/or services with program funds may not be in compliance with the Uniform Guidance. Questioned Costs: Not applicable. Context: The System’s internal procurement policy has not been reviewed to incorporate all of the required provisions within 2 CFR 200.318 through 200.327. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: The System should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials: Management concurs with this finding and is currently drafting a procurement policy to incorporate the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds.
Finding Reference: 2023-001 – I. Procurement, Suspension and Debarment Information on the Federal Program: Grantor: Department of the Treasury Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Criteria or Specific Requirement: For compliance requirement I.1 Procurement, Nuvance Health and Subsidiaries (the “System”) must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. The System may also use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: As part of our testing over the operating effectiveness of internal controls over the Procurement compliance requirement, we noted that the System did not have a procurement policy that conforms to all applicable federal laws, State and Local Fiscal Recovery Funds Regulations, and the standards contained in the Uniform Guidance, as applicable, when purchasing services with the federal funds related to the program. Cause: The System did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving federal funds related to the program. Effect or Potential Effect: Purchasing of goods and/or services with program funds may not be in compliance with the Uniform Guidance. Questioned Costs: Not applicable. Context: The System’s internal procurement policy has not been reviewed to incorporate all of the required provisions within 2 CFR 200.318 through 200.327. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: The System should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials: Management concurs with this finding and is currently drafting a procurement policy to incorporate the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds.