Audit 317903

FY End
2022-12-31
Total Expended
$56.73M
Findings
2
Programs
24
Year: 2022 Accepted: 2024-08-26

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
485114 2022-001 - - P
1061556 2022-001 - - P

Programs

ALN Program Spent Major Findings
10.766 Community Facilities Loans and Grants $22.78M Yes 0
93.498 Covid-19 Provider Relief Fund (prf) and American Rescue Plan (arp)- Camc $13.31M Yes 0
97.036 Covid-19 Disasater Grants- Public Assistance $7.14M Yes 0
93.498 Covid-19 Provider Relief Funds (prf) and American Rescue Plan (arp)- Mhs $7.05M Yes 1
93.493 Congressional Directives $3.41M Yes 0
93.918 Provide Outpatients Dis with Respect of Hiv Disease $1.27M - 0
93.788 State Opioid Response $420,593 - 0
93.917 Hiv Care Formula Grants $359,479 - 0
93.859 Biomedical Research and Research Training $266,020 - 0
16.575 Crime Victim Assistance $168,041 - 0
93.778 Medical Assistance Program $126,718 - 0
93.461 Covid-19 Testing for the Uninsured $122,271 - 0
10.561 Supplemental Nutrition Assistance Program, Education Snap $106,868 - 0
93.991 Preventive Health and Health Services Block Grant / Diabetes Education and Prevention (bph - Keys) $45,157 - 0
93.124 Nurse Anesthetist Traineeships $35,993 - 0
93.319 Outreach Program to Reduce the Prevalence of Obesity $27,035 - 0
93.395 National Clinical Trials Network Grant $25,447 - 0
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $17,100 - 0
93.650 Accountable Health Communities $16,738 - 0
93.003 Public Health and Social Services Emergency Fund $14,047 - 0
93.110 Maternal and Child Health Federal Consolidated Programs $13,021 - 0
93.889 Covid-19 Aspr Hospital Association Covid Supplement $11,100 - 0
93.365 Sickle Cell Treatment Demonstration Program $7,807 - 0
93.918 Covid-19 Ryan White Response $770 - 0

Contacts

Name Title Type
E9JGWHKWLSE5 Deloitte & Touche LLP Auditee
4123387513 Lacey Anderson Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance where applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass‐through entity identifying numbers are presented where available. For the purposes of the Schedule, federal awards include the following: • Direct federal awards • Pass-through funds received from nonfederal organizations under federally sponsored programs conducted by those organizations • The amounts reported for the COVID-19 Disaster Grants- Public Assistance (ALN 97.036) are based on expenditures incurred in a prior year. • The amounts reported for the COVID-19 Provider Relief Fund (ALN 93.498) are based on expenditures incurred in a prior year. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) includes the federal award activity of Vandalia Health, Inc. and Subsidiaries (the “System”) under programs of the federal government for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). These schedules include Provider Relief Funds (PRF) related to Monongalia Health System, Inc. (MHS), which was acquired by the System on September 1, 2022. Within the schedules, the PRF relating to MHS is marked "unaudited," on which no opinion was expressed by the auditors on such funds.
Title: SUBRECIPIENT DISBURSEMENTS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance where applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass‐through entity identifying numbers are presented where available. For the purposes of the Schedule, federal awards include the following: • Direct federal awards • Pass-through funds received from nonfederal organizations under federally sponsored programs conducted by those organizations • The amounts reported for the COVID-19 Disaster Grants- Public Assistance (ALN 97.036) are based on expenditures incurred in a prior year. • The amounts reported for the COVID-19 Provider Relief Fund (ALN 93.498) are based on expenditures incurred in a prior year. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The System made subrecipient disbursements of $59,017 to its subrecipient, Thomas Health Physician Partners, Inc., during the year ended December 31, 2022.
Title: LOAN/LOAN GUARANTEE OUTSTANDING BALANCES Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance where applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass‐through entity identifying numbers are presented where available. For the purposes of the Schedule, federal awards include the following: • Direct federal awards • Pass-through funds received from nonfederal organizations under federally sponsored programs conducted by those organizations • The amounts reported for the COVID-19 Disaster Grants- Public Assistance (ALN 97.036) are based on expenditures incurred in a prior year. • The amounts reported for the COVID-19 Provider Relief Fund (ALN 93.498) are based on expenditures incurred in a prior year. De Minimis Rate Used: N Rate Explanation: The System has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. COMMUNITY FACILITIES LOANS AND GRANTS (10.766)—Balances outstanding at the end of the audit period were $22,776,216.

Finding Details

Disclaimer of Opinion relating to ALN#93.498 COVID-19 Provider Relief Funds (PRF) and American Rescue Plan (ARP)—MHS Condition—The accompanying Schedule of Expenditures of Federal Awards (“SEFA”) includes the COVID-19 Provider Relief Funds and American Rescue Plan (“PRF”) programs for Monongalia Health System, Inc (MHS), which was acquired by the System in September 2022. Under the PRF federal reporting guidance, MHS’s PRF program should be included on the SEFA no earlier than fiscal year end of December 31, 2022. It is appropriate for MHS’s PRF to be included on the consolidated SEFA as of December 31, 2022. However, PRF are unique in that the compliance requirements apply to MHS operational results from prior periods which predate the business acquisition and were audited by other auditors. As such, the MHS PRF is unaudited. Effect—The auditors are faced with practical challenges to access all the financial records or obtain sufficient corroborative evidence from these periods before the acquisition. Consequently, we were unable to obtain sufficient appropriate audit evidence for the direct and material compliance requirements and therefore, we were unable to perform any audit procedures on the COVID-19 Provider Relief funds and American Rescue Plan program related to MHS as of December 31, 2022, and we do not express an opinion on the compliance of MHS with the specific requirements of PRF. Cause—Monongalia Health System, Inc (MHS) was acquired by the System in September 2022. As an acquired entity, MHS changed its fiscal year end from June 30th to December 31st to align with the System’s fiscal year-end. MHS was officially consolidated with the System’s financial statements as of fiscal year end December 31, 2022. Therefore, there are practical challenges to report the PRF balances reportable on the December 31, 2022 SEFA as the lost revenues and expenditures relate to periods audited by the predecessor auditor. Criteria—Based on CFR § 200.518 Major program determination, MHS’s PRF program is classified as a high-risk type A program and therefore, a major program. However, due to the circumstances detailed above, the auditors are not able to issue an opinion for the program. Context/Perspective—This issue is isolated to MHS PRF funds that were reportable as a of December 31, 2022 but the underlying lost revenue and expenses related to periods prior to the System’s acquisition of MHS on September 1, 2022. As there is no clear guidance in member substitution transactions that cross over reporting periods, the System has included the program on the SEFA; however, the auditors were unable to audit the program. Questioned Costs—There were approximately $7,051,383 of MHS PRF monies reported on the SEFA. Recommendation—We recommend that the System obtain approval from department of HHS and other regulatory authorities and agree to a path forward when member substitutions arise to determine the most appropriate reporting treatment and allow for a practical audit of funds. Views of Responsible Officials and Planned Corrective Action—Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.
Disclaimer of Opinion relating to ALN#93.498 COVID-19 Provider Relief Funds (PRF) and American Rescue Plan (ARP)—MHS Condition—The accompanying Schedule of Expenditures of Federal Awards (“SEFA”) includes the COVID-19 Provider Relief Funds and American Rescue Plan (“PRF”) programs for Monongalia Health System, Inc (MHS), which was acquired by the System in September 2022. Under the PRF federal reporting guidance, MHS’s PRF program should be included on the SEFA no earlier than fiscal year end of December 31, 2022. It is appropriate for MHS’s PRF to be included on the consolidated SEFA as of December 31, 2022. However, PRF are unique in that the compliance requirements apply to MHS operational results from prior periods which predate the business acquisition and were audited by other auditors. As such, the MHS PRF is unaudited. Effect—The auditors are faced with practical challenges to access all the financial records or obtain sufficient corroborative evidence from these periods before the acquisition. Consequently, we were unable to obtain sufficient appropriate audit evidence for the direct and material compliance requirements and therefore, we were unable to perform any audit procedures on the COVID-19 Provider Relief funds and American Rescue Plan program related to MHS as of December 31, 2022, and we do not express an opinion on the compliance of MHS with the specific requirements of PRF. Cause—Monongalia Health System, Inc (MHS) was acquired by the System in September 2022. As an acquired entity, MHS changed its fiscal year end from June 30th to December 31st to align with the System’s fiscal year-end. MHS was officially consolidated with the System’s financial statements as of fiscal year end December 31, 2022. Therefore, there are practical challenges to report the PRF balances reportable on the December 31, 2022 SEFA as the lost revenues and expenditures relate to periods audited by the predecessor auditor. Criteria—Based on CFR § 200.518 Major program determination, MHS’s PRF program is classified as a high-risk type A program and therefore, a major program. However, due to the circumstances detailed above, the auditors are not able to issue an opinion for the program. Context/Perspective—This issue is isolated to MHS PRF funds that were reportable as a of December 31, 2022 but the underlying lost revenue and expenses related to periods prior to the System’s acquisition of MHS on September 1, 2022. As there is no clear guidance in member substitution transactions that cross over reporting periods, the System has included the program on the SEFA; however, the auditors were unable to audit the program. Questioned Costs—There were approximately $7,051,383 of MHS PRF monies reported on the SEFA. Recommendation—We recommend that the System obtain approval from department of HHS and other regulatory authorities and agree to a path forward when member substitutions arise to determine the most appropriate reporting treatment and allow for a practical audit of funds. Views of Responsible Officials and Planned Corrective Action—Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.