Audit 312296

FY End
2022-12-31
Total Expended
$29.13M
Findings
16
Programs
20
Organization: Novant Health, Inc. (NC)
Year: 2022 Accepted: 2023-09-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
421362 2022-001 - - L
421363 2022-001 - - L
421364 2022-002 Significant Deficiency - I
421365 2022-002 Significant Deficiency - I
421366 2022-002 Significant Deficiency - I
421367 2022-003 Significant Deficiency - F
421368 2022-003 Significant Deficiency - F
421369 2022-003 Significant Deficiency - F
997804 2022-001 - - L
997805 2022-001 - - L
997806 2022-002 Significant Deficiency - I
997807 2022-002 Significant Deficiency - I
997808 2022-002 Significant Deficiency - I
997809 2022-003 Significant Deficiency - F
997810 2022-003 Significant Deficiency - F
997811 2022-003 Significant Deficiency - F

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $20.79M Yes 0
93.461 Covid-19 Testing for the Uninsured $4.10M Yes 0
32.006 Covid-19 Telehealth Program $1.12M - 0
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $313,575 - 0
93.889 National Bioterrorism Hospital Preparedness Program $260,655 Yes 2
93.778 Medical Assistance Program $211,892 - 0
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $131,539 Yes 1
93.155 Rural Health Research Centers $126,120 - 0
93.917 Hiv Care Formula Grants $111,074 - 0
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $88,295 - 0
93.110 Maternal and Child Health Federal Consolidated Programs $83,324 - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $41,152 - 0
93.810 Paul Coverdell National Acute Stroke Program National Center for Chronic Disease Prevention and Health Promotion $35,175 - 0
93.226 Research on Healthcare Costs, Quality and Outcomes $17,308 - 0
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $15,661 - 0
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $12,308 - 0
93.865 Child Health and Human Development Extramural Research $4,309 - 0
93.470 Alzheimer's Disease Program Initiative (adpi) $3,391 - 0
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $2,426 - 0
93.969 Pphf Geriatric Education Centers $850 - 0

Contacts

Name Title Type
XNV6X5K8UB63 Brad Woolery Auditee
3362771026 Angela Konkle Auditor
No contacts on file

Notes to SEFA

Title: COVID-19 HRSA Claims Reimbursement for the Uninsured Program Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of Novant Health, Inc. and Affiliates (Novant Health) and is presented on the accrual basis of accounting. The information in the Schedule is presented in accordance with 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 the federal award activity of Novant Health, it is not intended to and does not present the financial position, changes in net assets and cash flows of Novant Health. The purpose of the Schedule is to present a summary of those activities of Novant Health for the year ended December 31, 2022, which have been financed by federal awards. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, Novant Health did not make this election and uses a negotiated indirect cost rate when charging indirect costs to federal awards. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between Novant Health and agencies and departments of the federal government and all sub-awards to Novant Health by non-federal organizations pursuant to federal grants, contracts and similar agreements. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Novant Health conducted COVID-19 testing and/or provided treatment for uninsured individuals with a COVID-19 primary diagnosis on or after February 4, 2020 and as such has requested claims reimbursement under the Department of Health and Human Service (HHS)s COVID-19 Health Resources and Services Administration's ("HRSA") Claims Reimbursement for the Uninsured Program (Assistance Listing #93.461).Novant Health recorded $4,097,977 on the Schedule which represents all payments received in 2022 from HRSA. There were no significant adjustments in 2022 related to 2021 claims. HRSA announced that the program was ending and no claims could be submitted after March 22, 2022 (for testing or treatment) or April 5, 2022 (for vaccine administration) and because of that Novant Health does not expect to receive any additional payments from HRSA for claims with dates of service through 2022.
Title: Department of Health and Human Services Provider Relief Funds Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of Novant Health, Inc. and Affiliates (Novant Health) and is presented on the accrual basis of accounting. The information in the Schedule is presented in accordance with 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 the federal award activity of Novant Health, it is not intended to and does not present the financial position, changes in net assets and cash flows of Novant Health. The purpose of the Schedule is to present a summary of those activities of Novant Health for the year ended December 31, 2022, which have been financed by federal awards. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, Novant Health did not make this election and uses a negotiated indirect cost rate when charging indirect costs to federal awards. For purposes of the Schedule, federal awards include all grants, contracts and similar agreements entered into directly between Novant Health and agencies and departments of the federal government and all sub-awards to Novant Health by non-federal organizations pursuant to federal grants, contracts and similar agreements. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Schedule includes grant activity related to HHSs Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution (Assistance Listing #93.498). As required based on guidance in the 2022 OMB Compliance Supplement, the Schedule includes all Period 3 funds received between January 1, 2021 and June 30, 2021 and expended by June 30, 2022 and all Period 4 funds received between July 1, 2021 and December 31, 2021 and expended by December 31, 2022, as reported to HRSA via the PRF Reporting Portal. The Schedule thus includes $19,073,138 of direct expenditures and $1,720,361 in lost revenue. Given the timing covered by Period 3 and Period 4 funds, certain of these expenses were reflected in Novant Healths consolidated statement of operations for the year ended December 31, 2001. Additionally, lost revenue does not represent an expenditure in the Novant Health financial statements and thus is a reconciling item between the federal expenses in the financial statements and the amount included on the Schedule.

Finding Details

2022-001: First tier subawards were not reported on the Federal Funding Accountability and Transparency Act Subaward Reporting System (?FSRS?)Cluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: Coordinated Services and Access to Research for Women, Infants, Children, and Youth (?Ryan White Part D Program?)Award #: 7 H12HA45378-01-00; 2 H12HA45378-02-00Assistance Listing #: 93.153Award Year: Fiscal year 2022Pass-through entity: N/ACondition:As part of PwC?s testing over the reporting requirements related to the Ryan White Part D Program, we identified a first tier subaward to Duke University in the amount of $128,218 during fiscal year 2022, and this subaward was not reported within the FSRS system, as required.Criteria:The Federal Funding Accountability and Transparency Act (?FFATA?) of 2006 requires full disclosure of all entities and organizations receiving federal funds, including grants, contracts, loans, and other assistance and payments. Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report in the FSRS system by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.Cause:Management did not perform a thorough review of the contract, which noted the FSRS reporting requirement related to subawards that was relevant to the Company and as such, they failed to file the required notification of subaward within the FSRS system for Duke University, a first tier subrecipient under the Ryan White Part D Program.Effect:The appropriate report was not filed and as such, the FSRS system did not appropriately include the first tier subaward from Novant Health to Duke University under the Ryan White Part D Program for fiscal year 2022.Recommendation:We recommend the Company implement a contract summarization control whereby the grant accountant (or designee) summarize all relevant aspects of the contract(s) for the fiscal year. This summary should then be reviewed by the grant/program coordinator prior to the start of the contract to ensure that all relevant requirements are included within the summary and to discuss with the appropriate individuals the plan to execute on each requirement.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-001: First tier subawards were not reported on the Federal Funding Accountability and Transparency Act Subaward Reporting System (?FSRS?)Cluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: Coordinated Services and Access to Research for Women, Infants, Children, and Youth (?Ryan White Part D Program?)Award #: 7 H12HA45378-01-00; 2 H12HA45378-02-00Assistance Listing #: 93.153Award Year: Fiscal year 2022Pass-through entity: N/ACondition:As part of PwC?s testing over the reporting requirements related to the Ryan White Part D Program, we identified a first tier subaward to Duke University in the amount of $128,218 during fiscal year 2022, and this subaward was not reported within the FSRS system, as required.Criteria:The Federal Funding Accountability and Transparency Act (?FFATA?) of 2006 requires full disclosure of all entities and organizations receiving federal funds, including grants, contracts, loans, and other assistance and payments. Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report in the FSRS system by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.Cause:Management did not perform a thorough review of the contract, which noted the FSRS reporting requirement related to subawards that was relevant to the Company and as such, they failed to file the required notification of subaward within the FSRS system for Duke University, a first tier subrecipient under the Ryan White Part D Program.Effect:The appropriate report was not filed and as such, the FSRS system did not appropriately include the first tier subaward from Novant Health to Duke University under the Ryan White Part D Program for fiscal year 2022.Recommendation:We recommend the Company implement a contract summarization control whereby the grant accountant (or designee) summarize all relevant aspects of the contract(s) for the fiscal year. This summary should then be reviewed by the grant/program coordinator prior to the start of the contract to ensure that all relevant requirements are included within the summary and to discuss with the appropriate individuals the plan to execute on each requirement.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-002: Evidence of vendor suspension and debarment checks for vendors was not retained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Assistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: N/ACondition:The Company has a policy by which all new vendors are required to be checked against the SAM.gov database by the Risk Management department prior to being entered into the accounts payable system regardless of the dollar value of the transaction. Through inquiry with the Company, they indicated that while these checks are performed, evidence of the checks is not retained. Additionally, of the 179 unique vendors used during fiscal year 2022 related to the Bioterrorism Program, PwC was unable to obtain information regarding how many were new vendors and thus subject to this check. For context, however, if the Company used the federal threshold of $25k for completing the SAM.gov checks, there were 4 transactions totaling approximately $420k above this threshold.Criteria:Non-federal entities are prohibited from contracting with or making subawards under covered transactionsto parties that are suspended or debarred. When a non-federal entity enters into a covered transactionwith an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded fromparticipating in the transaction. This verification may be accomplished by (1) checking the System forAward Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting acertification from the entity, or (3) adding a clause or condition to the covered transaction with that entity(2 CFR section 180.300).Cause:Management?s process and controls did not include the applicable requirement of retaining history or evidence of SAM.gov vendor checks for vendors utilized by the program. As such, no single individual within the Risk Management department at the Company was retaining history or evidence of this step in the Company?s procurement and vendor setup process.Effect:The Company may do business with a vendor that is suspended or debarred if timely checks are not performed.Recommendation:We recommend the Company enhance its controls and revise its procedures surrounding vendor suspension and debarment to include a requirement that evidence is appropriately maintained of SAM.gov vendor checks for each vendor (e.g. screenshots, a checklist including this procedure that is signed, etc.).Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-002: Evidence of vendor suspension and debarment checks for vendors was not retained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Assistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: N/ACondition:The Company has a policy by which all new vendors are required to be checked against the SAM.gov database by the Risk Management department prior to being entered into the accounts payable system regardless of the dollar value of the transaction. Through inquiry with the Company, they indicated that while these checks are performed, evidence of the checks is not retained. Additionally, of the 179 unique vendors used during fiscal year 2022 related to the Bioterrorism Program, PwC was unable to obtain information regarding how many were new vendors and thus subject to this check. For context, however, if the Company used the federal threshold of $25k for completing the SAM.gov checks, there were 4 transactions totaling approximately $420k above this threshold.Criteria:Non-federal entities are prohibited from contracting with or making subawards under covered transactionsto parties that are suspended or debarred. When a non-federal entity enters into a covered transactionwith an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded fromparticipating in the transaction. This verification may be accomplished by (1) checking the System forAward Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting acertification from the entity, or (3) adding a clause or condition to the covered transaction with that entity(2 CFR section 180.300).Cause:Management?s process and controls did not include the applicable requirement of retaining history or evidence of SAM.gov vendor checks for vendors utilized by the program. As such, no single individual within the Risk Management department at the Company was retaining history or evidence of this step in the Company?s procurement and vendor setup process.Effect:The Company may do business with a vendor that is suspended or debarred if timely checks are not performed.Recommendation:We recommend the Company enhance its controls and revise its procedures surrounding vendor suspension and debarment to include a requirement that evidence is appropriately maintained of SAM.gov vendor checks for each vendor (e.g. screenshots, a checklist including this procedure that is signed, etc.).Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-002: Evidence of vendor suspension and debarment checks for vendors was not retained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Assistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: N/ACondition:The Company has a policy by which all new vendors are required to be checked against the SAM.gov database by the Risk Management department prior to being entered into the accounts payable system regardless of the dollar value of the transaction. Through inquiry with the Company, they indicated that while these checks are performed, evidence of the checks is not retained. Additionally, of the 179 unique vendors used during fiscal year 2022 related to the Bioterrorism Program, PwC was unable to obtain information regarding how many were new vendors and thus subject to this check. For context, however, if the Company used the federal threshold of $25k for completing the SAM.gov checks, there were 4 transactions totaling approximately $420k above this threshold.Criteria:Non-federal entities are prohibited from contracting with or making subawards under covered transactionsto parties that are suspended or debarred. When a non-federal entity enters into a covered transactionwith an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded fromparticipating in the transaction. This verification may be accomplished by (1) checking the System forAward Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting acertification from the entity, or (3) adding a clause or condition to the covered transaction with that entity(2 CFR section 180.300).Cause:Management?s process and controls did not include the applicable requirement of retaining history or evidence of SAM.gov vendor checks for vendors utilized by the program. As such, no single individual within the Risk Management department at the Company was retaining history or evidence of this step in the Company?s procurement and vendor setup process.Effect:The Company may do business with a vendor that is suspended or debarred if timely checks are not performed.Recommendation:We recommend the Company enhance its controls and revise its procedures surrounding vendor suspension and debarment to include a requirement that evidence is appropriately maintained of SAM.gov vendor checks for each vendor (e.g. screenshots, a checklist including this procedure that is signed, etc.).Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Condition:As part of our testing over the equipment compliance requirements related to the Bioterrorism Program, we noted no physical inventory of equipment performed by management that was purchased with federal funds since the inception of the grants in July 2019. Management has noted that routine maintenance checks are performed periodically on all equipment, however, we were unable to obtain management?s evidence of these checks for our 25 selections. At the end of the fiscal year, there were approximately 225 pieces of equipment with a value of approximately $800,000.Criteria:2 CFR 200.313 d(2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.Cause:Management?s process and controls do not include performing a formal physical inventory of federal equipment and retaining evidence of this process at least once every two years and management was not aware of this requirement.Effect:The Company may not maintain complete and accurate property records or safeguard equipment appropriately.Recommendation:We recommend the Company create a control and revise its process surrounding physical inventories of equipment to include a requirement that the inventory is completed in accordance with the criteria noted above. Additionally, a full inventory of all equipment should be performed as soon as practical.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Condition:As part of our testing over the equipment compliance requirements related to the Bioterrorism Program, we noted no physical inventory of equipment performed by management that was purchased with federal funds since the inception of the grants in July 2019. Management has noted that routine maintenance checks are performed periodically on all equipment, however, we were unable to obtain management?s evidence of these checks for our 25 selections. At the end of the fiscal year, there were approximately 225 pieces of equipment with a value of approximately $800,000.Criteria:2 CFR 200.313 d(2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.Cause:Management?s process and controls do not include performing a formal physical inventory of federal equipment and retaining evidence of this process at least once every two years and management was not aware of this requirement.Effect:The Company may not maintain complete and accurate property records or safeguard equipment appropriately.Recommendation:We recommend the Company create a control and revise its process surrounding physical inventories of equipment to include a requirement that the inventory is completed in accordance with the criteria noted above. Additionally, a full inventory of all equipment should be performed as soon as practical.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Condition:As part of our testing over the equipment compliance requirements related to the Bioterrorism Program, we noted no physical inventory of equipment performed by management that was purchased with federal funds since the inception of the grants in July 2019. Management has noted that routine maintenance checks are performed periodically on all equipment, however, we were unable to obtain management?s evidence of these checks for our 25 selections. At the end of the fiscal year, there were approximately 225 pieces of equipment with a value of approximately $800,000.Criteria:2 CFR 200.313 d(2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.Cause:Management?s process and controls do not include performing a formal physical inventory of federal equipment and retaining evidence of this process at least once every two years and management was not aware of this requirement.Effect:The Company may not maintain complete and accurate property records or safeguard equipment appropriately.Recommendation:We recommend the Company create a control and revise its process surrounding physical inventories of equipment to include a requirement that the inventory is completed in accordance with the criteria noted above. Additionally, a full inventory of all equipment should be performed as soon as practical.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-001: First tier subawards were not reported on the Federal Funding Accountability and Transparency Act Subaward Reporting System (?FSRS?)Cluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: Coordinated Services and Access to Research for Women, Infants, Children, and Youth (?Ryan White Part D Program?)Award #: 7 H12HA45378-01-00; 2 H12HA45378-02-00Assistance Listing #: 93.153Award Year: Fiscal year 2022Pass-through entity: N/ACondition:As part of PwC?s testing over the reporting requirements related to the Ryan White Part D Program, we identified a first tier subaward to Duke University in the amount of $128,218 during fiscal year 2022, and this subaward was not reported within the FSRS system, as required.Criteria:The Federal Funding Accountability and Transparency Act (?FFATA?) of 2006 requires full disclosure of all entities and organizations receiving federal funds, including grants, contracts, loans, and other assistance and payments. Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report in the FSRS system by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.Cause:Management did not perform a thorough review of the contract, which noted the FSRS reporting requirement related to subawards that was relevant to the Company and as such, they failed to file the required notification of subaward within the FSRS system for Duke University, a first tier subrecipient under the Ryan White Part D Program.Effect:The appropriate report was not filed and as such, the FSRS system did not appropriately include the first tier subaward from Novant Health to Duke University under the Ryan White Part D Program for fiscal year 2022.Recommendation:We recommend the Company implement a contract summarization control whereby the grant accountant (or designee) summarize all relevant aspects of the contract(s) for the fiscal year. This summary should then be reviewed by the grant/program coordinator prior to the start of the contract to ensure that all relevant requirements are included within the summary and to discuss with the appropriate individuals the plan to execute on each requirement.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-001: First tier subawards were not reported on the Federal Funding Accountability and Transparency Act Subaward Reporting System (?FSRS?)Cluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: Coordinated Services and Access to Research for Women, Infants, Children, and Youth (?Ryan White Part D Program?)Award #: 7 H12HA45378-01-00; 2 H12HA45378-02-00Assistance Listing #: 93.153Award Year: Fiscal year 2022Pass-through entity: N/ACondition:As part of PwC?s testing over the reporting requirements related to the Ryan White Part D Program, we identified a first tier subaward to Duke University in the amount of $128,218 during fiscal year 2022, and this subaward was not reported within the FSRS system, as required.Criteria:The Federal Funding Accountability and Transparency Act (?FFATA?) of 2006 requires full disclosure of all entities and organizations receiving federal funds, including grants, contracts, loans, and other assistance and payments. Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report in the FSRS system by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.Cause:Management did not perform a thorough review of the contract, which noted the FSRS reporting requirement related to subawards that was relevant to the Company and as such, they failed to file the required notification of subaward within the FSRS system for Duke University, a first tier subrecipient under the Ryan White Part D Program.Effect:The appropriate report was not filed and as such, the FSRS system did not appropriately include the first tier subaward from Novant Health to Duke University under the Ryan White Part D Program for fiscal year 2022.Recommendation:We recommend the Company implement a contract summarization control whereby the grant accountant (or designee) summarize all relevant aspects of the contract(s) for the fiscal year. This summary should then be reviewed by the grant/program coordinator prior to the start of the contract to ensure that all relevant requirements are included within the summary and to discuss with the appropriate individuals the plan to execute on each requirement.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-002: Evidence of vendor suspension and debarment checks for vendors was not retained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Assistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: N/ACondition:The Company has a policy by which all new vendors are required to be checked against the SAM.gov database by the Risk Management department prior to being entered into the accounts payable system regardless of the dollar value of the transaction. Through inquiry with the Company, they indicated that while these checks are performed, evidence of the checks is not retained. Additionally, of the 179 unique vendors used during fiscal year 2022 related to the Bioterrorism Program, PwC was unable to obtain information regarding how many were new vendors and thus subject to this check. For context, however, if the Company used the federal threshold of $25k for completing the SAM.gov checks, there were 4 transactions totaling approximately $420k above this threshold.Criteria:Non-federal entities are prohibited from contracting with or making subawards under covered transactionsto parties that are suspended or debarred. When a non-federal entity enters into a covered transactionwith an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded fromparticipating in the transaction. This verification may be accomplished by (1) checking the System forAward Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting acertification from the entity, or (3) adding a clause or condition to the covered transaction with that entity(2 CFR section 180.300).Cause:Management?s process and controls did not include the applicable requirement of retaining history or evidence of SAM.gov vendor checks for vendors utilized by the program. As such, no single individual within the Risk Management department at the Company was retaining history or evidence of this step in the Company?s procurement and vendor setup process.Effect:The Company may do business with a vendor that is suspended or debarred if timely checks are not performed.Recommendation:We recommend the Company enhance its controls and revise its procedures surrounding vendor suspension and debarment to include a requirement that evidence is appropriately maintained of SAM.gov vendor checks for each vendor (e.g. screenshots, a checklist including this procedure that is signed, etc.).Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-002: Evidence of vendor suspension and debarment checks for vendors was not retained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Assistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: N/ACondition:The Company has a policy by which all new vendors are required to be checked against the SAM.gov database by the Risk Management department prior to being entered into the accounts payable system regardless of the dollar value of the transaction. Through inquiry with the Company, they indicated that while these checks are performed, evidence of the checks is not retained. Additionally, of the 179 unique vendors used during fiscal year 2022 related to the Bioterrorism Program, PwC was unable to obtain information regarding how many were new vendors and thus subject to this check. For context, however, if the Company used the federal threshold of $25k for completing the SAM.gov checks, there were 4 transactions totaling approximately $420k above this threshold.Criteria:Non-federal entities are prohibited from contracting with or making subawards under covered transactionsto parties that are suspended or debarred. When a non-federal entity enters into a covered transactionwith an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded fromparticipating in the transaction. This verification may be accomplished by (1) checking the System forAward Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting acertification from the entity, or (3) adding a clause or condition to the covered transaction with that entity(2 CFR section 180.300).Cause:Management?s process and controls did not include the applicable requirement of retaining history or evidence of SAM.gov vendor checks for vendors utilized by the program. As such, no single individual within the Risk Management department at the Company was retaining history or evidence of this step in the Company?s procurement and vendor setup process.Effect:The Company may do business with a vendor that is suspended or debarred if timely checks are not performed.Recommendation:We recommend the Company enhance its controls and revise its procedures surrounding vendor suspension and debarment to include a requirement that evidence is appropriately maintained of SAM.gov vendor checks for each vendor (e.g. screenshots, a checklist including this procedure that is signed, etc.).Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-002: Evidence of vendor suspension and debarment checks for vendors was not retained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Assistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: N/ACondition:The Company has a policy by which all new vendors are required to be checked against the SAM.gov database by the Risk Management department prior to being entered into the accounts payable system regardless of the dollar value of the transaction. Through inquiry with the Company, they indicated that while these checks are performed, evidence of the checks is not retained. Additionally, of the 179 unique vendors used during fiscal year 2022 related to the Bioterrorism Program, PwC was unable to obtain information regarding how many were new vendors and thus subject to this check. For context, however, if the Company used the federal threshold of $25k for completing the SAM.gov checks, there were 4 transactions totaling approximately $420k above this threshold.Criteria:Non-federal entities are prohibited from contracting with or making subawards under covered transactionsto parties that are suspended or debarred. When a non-federal entity enters into a covered transactionwith an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded fromparticipating in the transaction. This verification may be accomplished by (1) checking the System forAward Management (SAM) Exclusions maintained by the General Services Administration, (2) collecting acertification from the entity, or (3) adding a clause or condition to the covered transaction with that entity(2 CFR section 180.300).Cause:Management?s process and controls did not include the applicable requirement of retaining history or evidence of SAM.gov vendor checks for vendors utilized by the program. As such, no single individual within the Risk Management department at the Company was retaining history or evidence of this step in the Company?s procurement and vendor setup process.Effect:The Company may do business with a vendor that is suspended or debarred if timely checks are not performed.Recommendation:We recommend the Company enhance its controls and revise its procedures surrounding vendor suspension and debarment to include a requirement that evidence is appropriately maintained of SAM.gov vendor checks for each vendor (e.g. screenshots, a checklist including this procedure that is signed, etc.).Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Condition:As part of our testing over the equipment compliance requirements related to the Bioterrorism Program, we noted no physical inventory of equipment performed by management that was purchased with federal funds since the inception of the grants in July 2019. Management has noted that routine maintenance checks are performed periodically on all equipment, however, we were unable to obtain management?s evidence of these checks for our 25 selections. At the end of the fiscal year, there were approximately 225 pieces of equipment with a value of approximately $800,000.Criteria:2 CFR 200.313 d(2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.Cause:Management?s process and controls do not include performing a formal physical inventory of federal equipment and retaining evidence of this process at least once every two years and management was not aware of this requirement.Effect:The Company may not maintain complete and accurate property records or safeguard equipment appropriately.Recommendation:We recommend the Company create a control and revise its process surrounding physical inventories of equipment to include a requirement that the inventory is completed in accordance with the criteria noted above. Additionally, a full inventory of all equipment should be performed as soon as practical.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Condition:As part of our testing over the equipment compliance requirements related to the Bioterrorism Program, we noted no physical inventory of equipment performed by management that was purchased with federal funds since the inception of the grants in July 2019. Management has noted that routine maintenance checks are performed periodically on all equipment, however, we were unable to obtain management?s evidence of these checks for our 25 selections. At the end of the fiscal year, there were approximately 225 pieces of equipment with a value of approximately $800,000.Criteria:2 CFR 200.313 d(2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.Cause:Management?s process and controls do not include performing a formal physical inventory of federal equipment and retaining evidence of this process at least once every two years and management was not aware of this requirement.Effect:The Company may not maintain complete and accurate property records or safeguard equipment appropriately.Recommendation:We recommend the Company create a control and revise its process surrounding physical inventories of equipment to include a requirement that the inventory is completed in accordance with the criteria noted above. Additionally, a full inventory of all equipment should be performed as soon as practical.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2022-003: Evidence of physical inspection of equipment purchased with federal funds was not maintained ? Significant deficiencyCluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: COVID-19 National Bioterrorism Hospital Preparedness Program (?Bioterrorism Program?)Award #: N/AAssistance Listing #: 93.889Award Year: Fiscal year 2022Pass-through entity: North Carolina Healthcare Foundation; North Carolina Department of Health and Human Services ? Division of Health Service Regulation, Office of Emergency Medical ServicesPass-through award #: U3REP 200659; 42705; 44024Condition:As part of our testing over the equipment compliance requirements related to the Bioterrorism Program, we noted no physical inventory of equipment performed by management that was purchased with federal funds since the inception of the grants in July 2019. Management has noted that routine maintenance checks are performed periodically on all equipment, however, we were unable to obtain management?s evidence of these checks for our 25 selections. At the end of the fiscal year, there were approximately 225 pieces of equipment with a value of approximately $800,000.Criteria:2 CFR 200.313 d(2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.Cause:Management?s process and controls do not include performing a formal physical inventory of federal equipment and retaining evidence of this process at least once every two years and management was not aware of this requirement.Effect:The Company may not maintain complete and accurate property records or safeguard equipment appropriately.Recommendation:We recommend the Company create a control and revise its process surrounding physical inventories of equipment to include a requirement that the inventory is completed in accordance with the criteria noted above. Additionally, a full inventory of all equipment should be performed as soon as practical.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.