Audit 317453

FY End
2023-10-31
Total Expended
$8.99M
Findings
2
Programs
5
Organization: Vail Health Services (CO)
Year: 2023 Accepted: 2024-08-19

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
481435 2023-001 Significant Deficiency - M
1057877 2023-001 Significant Deficiency - M

Contacts

Name Title Type
KYETWC1L3AP3 Chelsea Helmkamp Auditee
9707772811 Debra Bowes Auditor
No contacts on file

Notes to SEFA

Title: 4. Provider Relief Fund and American Rescue Plan Rural Distribution Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of Vail Health Services and Subsidiaries (collectively, the Organization) under programs of the federal government for the year ended October 31, 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 Organization, it is not intended to and does not present the financial position, changes in net position or cash flows of the Organization. Expenditures reported on the Schedule are reported on the accrual basis of accounting, with the exception of expenditures associated with the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) and the expenditures associated with Disaster Grants – Public Assistance (Presidentially Declare Disasters). 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. • PRF expenditures are reported based upon the timing of reporting periods in accordance with guidance provided by the Health Resources and Services Administration (HRSA). The terms and conditions of the award allow for reimbursement of actual expenses incurred and lost revenues. The Organization's methodology for calculating lost revenues was an alternative reasonable methodology under Option 3 for Vail Clinic, Inc. d/b/a Vail Health Hospital, Colorado Mountain Medical, LLC and VVMC Diversified Services d/b/a Vail Health Clinics. See Note 2 in the accompanying consolidated financial statements for a description on how the PRF funds were recorded in accordance with GAAP for 2023 and 2022. • Expenditures related to disaster grants are reported when the Organization has expended the necessary funds and the Federal Emergency Management Agency (FEMA) and its pass-through agency, the Colorado Division of Homeland Security and Emergency Management (DHSEM), have approved the expenditures for reimbursement. Expenditures on the Schedule that occurred prior to the reporting period and approved by FEMA/DHSEM during the reporting period were $4,053,257. De Minimis Rate Used: N Rate Explanation: The Organization has not elected to use the 10% de minimis indirect cost rate. For the U.S. Department of Health and Human Services (HHS) awards related to the PRF program, HHS has indicated the amounts on the Schedule be reported corresponding to reporting requirements of the HRS PRF Reporting Portal. Payments from HHS for PRF are assigned to "Payment Received Periods" (each, a Period) based upon the date each payment from the PRF was received. Each Period has a specified Period of Availability and timing of reporting requirements. Entities report into the HRSA PRF Reporting Portal after each Period's deadline to use the funds (i.e., after the end of the Period of Availability). The Schedule for the year ended October 31, 2023 includes amounts reported in the Period 4 and 5 Reports. Period 4 includes funds received between July 1, 2021 and December 31, 2021, and the deadline to use such funds was December 31, 2022. Period 5 includes funds received between January 1, 2022 and June 30, 2022, and the deadline to use such funds was June 30, 2023. Such amounts were recognized as a component of COVID-19 grant income in the Organization's consolidated statements of operations and changes in net assets during the years ended October 31, 2023 and 2022. Due to the PRF Reporting requirements, these amounts are not the total PRF received and/or recognized as COVID-19 grant income in the year presented in the Schedule. The Schedule includes the following entities that received funding under the PRF program: [See the Notes to the SEFA to chart/table]
Title: 5. Disaster Grants - Public Assistance (Presidentially Declared Disasters - Assistance Listing Number 97.036) Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal awards activity of Vail Health Services and Subsidiaries (collectively, the Organization) under programs of the federal government for the year ended October 31, 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 Organization, it is not intended to and does not present the financial position, changes in net position or cash flows of the Organization. Expenditures reported on the Schedule are reported on the accrual basis of accounting, with the exception of expenditures associated with the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) and the expenditures associated with Disaster Grants – Public Assistance (Presidentially Declare Disasters). 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. • PRF expenditures are reported based upon the timing of reporting periods in accordance with guidance provided by the Health Resources and Services Administration (HRSA). The terms and conditions of the award allow for reimbursement of actual expenses incurred and lost revenues. The Organization's methodology for calculating lost revenues was an alternative reasonable methodology under Option 3 for Vail Clinic, Inc. d/b/a Vail Health Hospital, Colorado Mountain Medical, LLC and VVMC Diversified Services d/b/a Vail Health Clinics. See Note 2 in the accompanying consolidated financial statements for a description on how the PRF funds were recorded in accordance with GAAP for 2023 and 2022. • Expenditures related to disaster grants are reported when the Organization has expended the necessary funds and the Federal Emergency Management Agency (FEMA) and its pass-through agency, the Colorado Division of Homeland Security and Emergency Management (DHSEM), have approved the expenditures for reimbursement. Expenditures on the Schedule that occurred prior to the reporting period and approved by FEMA/DHSEM during the reporting period were $4,053,257. De Minimis Rate Used: N Rate Explanation: The Organization has not elected to use the 10% de minimis indirect cost rate. The Federal Emergency Management Agency (FEMA) requires that FEMA has approved a project worksheet and that there have been eligible expenditures incurred for the approved project prior to reporting this program on the Schedule. In accordance with FEMA's guidance, the expenditures reported on the current year Schedule relate to amounts incurred and reported in the consolidated financial statements of the Corporation for the years ended October 31, 2021 and 2020.

Finding Details

Finding 2023-001 – Significant Deficiency in Internal Control - Subrecipient Monitoring Federal Program: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Federal Agency: U.S. Dept of Health and Human Services Passed-Through Agency: Colorado Department of Health Services Behavioral Health Division Award Number: 23 IBEH 175467 / 24 IBEH 184610 / 24 IBEH 187913 Award Year: 2023 and 2024 Compliance Requirement: Subrecipient Monitoring Questioned Costs: Not determinable Criteria: 2 CFR 200.332(a) requires that every subaward agreement includes certain information, including 1) subrecipient's unique entity identifier; 2) name of federal awarding agency; 3) assistance listing number and title; 4) identification of whether the award is R&D; and 5) indirect cost rate for the federal award (including if the de minimis rate is charged). 2 CFR 200.332(b) requires an evaluation of the subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of subawards as part of subrecipient monitoring and identifies specific considerations to be made during this process. 2 CFR 180.22 requires that contract awards not be made to parties listed on the government wide exclusions in the System for Award Management, which contains the names of parties debarred, suspended or otherwise excluded by agencies as well as parties declared ineligible under statutory or regulatory authority. Condition and Context: Subrecipient agreements entered into did not contain all required components as stipulated in 2 CFR 200.332(a). While the organization did have policies and procedures to evaluate its subrecipients, not all considerations noted in 2 CFR 200.332(b) are included in the policies. Furthermore, formal documentation was not maintained of specific considerations to the subrecipients that the Organization ultimately contracted with. Formal documentation was also not maintained related to verification that the subrecipients were not on the government wide exclusions list. Effect: Subrecipient agreements are missing certain data points that are required by the federal government. This could impact the subrecipients in their reporting. Lack of proper subrecipient monitoring, including the risk assessment component and verification of suspension/debarred status could result in the Organization entering into subrecipient agreements with organizations that will not comply with federal laws and regulations. Cause: The omitted components of the agreements, including lack of formal documentation of the risk assessment and verification that subrecipients were not on the federal governmentwide exclusions list were not detected by the Organization’s internal control process. Recommendation: We recommend that management implement procedures to ensure that future subrecipient agreements are compared against all requirements in 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22 and that formal documentation of such considerations be maintained. Planned Corrective Actions and View of Responsible Officials: Management agrees with the finding and is in the process of updating policies and procedures to be in compliance with the requirements of 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22.
Finding 2023-001 – Significant Deficiency in Internal Control - Subrecipient Monitoring Federal Program: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Federal Agency: U.S. Dept of Health and Human Services Passed-Through Agency: Colorado Department of Health Services Behavioral Health Division Award Number: 23 IBEH 175467 / 24 IBEH 184610 / 24 IBEH 187913 Award Year: 2023 and 2024 Compliance Requirement: Subrecipient Monitoring Questioned Costs: Not determinable Criteria: 2 CFR 200.332(a) requires that every subaward agreement includes certain information, including 1) subrecipient's unique entity identifier; 2) name of federal awarding agency; 3) assistance listing number and title; 4) identification of whether the award is R&D; and 5) indirect cost rate for the federal award (including if the de minimis rate is charged). 2 CFR 200.332(b) requires an evaluation of the subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of subawards as part of subrecipient monitoring and identifies specific considerations to be made during this process. 2 CFR 180.22 requires that contract awards not be made to parties listed on the government wide exclusions in the System for Award Management, which contains the names of parties debarred, suspended or otherwise excluded by agencies as well as parties declared ineligible under statutory or regulatory authority. Condition and Context: Subrecipient agreements entered into did not contain all required components as stipulated in 2 CFR 200.332(a). While the organization did have policies and procedures to evaluate its subrecipients, not all considerations noted in 2 CFR 200.332(b) are included in the policies. Furthermore, formal documentation was not maintained of specific considerations to the subrecipients that the Organization ultimately contracted with. Formal documentation was also not maintained related to verification that the subrecipients were not on the government wide exclusions list. Effect: Subrecipient agreements are missing certain data points that are required by the federal government. This could impact the subrecipients in their reporting. Lack of proper subrecipient monitoring, including the risk assessment component and verification of suspension/debarred status could result in the Organization entering into subrecipient agreements with organizations that will not comply with federal laws and regulations. Cause: The omitted components of the agreements, including lack of formal documentation of the risk assessment and verification that subrecipients were not on the federal governmentwide exclusions list were not detected by the Organization’s internal control process. Recommendation: We recommend that management implement procedures to ensure that future subrecipient agreements are compared against all requirements in 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22 and that formal documentation of such considerations be maintained. Planned Corrective Actions and View of Responsible Officials: Management agrees with the finding and is in the process of updating policies and procedures to be in compliance with the requirements of 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22.