Audit 322040

FY End
2023-12-31
Total Expended
$790.05M
Findings
2
Programs
27
Year: 2023 Accepted: 2024-09-28
Auditor: Ey

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
499241 2023-001 - - B
1075683 2023-001 - - B

Programs

ALN Program Spent Major Findings
14.151 Supplemental Loan Insurance_multifamily Rental Housing $375.81M - 0
93.498 Provider Relief Fund $116.68M Yes 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $93.23M Yes 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $15.66M Yes 0
93.268 Immunization Cooperative Agreements $7.12M - 0
16.575 Crime Victim Assistance $1.63M - 0
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B (b) $1.24M - 0
93.939 Hiv Prevention Activities_non-Governmental Organization Based $936,518 - 0
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $438,873 - 0
93.914 Hiv Emergency Relief Project Grants $438,373 - 0
93.217 Family Planning_services $301,934 - 0
93.884 Grants for Primary Care Training and Enhancement $289,678 - 0
93.994 Maternal and Child Health Services Block Grant to the States $271,593 - 0
93.924 Ryan White Hiv/aids Dental Reimbursement and Community Based Dental Partnership Grants $222,128 - 0
93.778 Medical Assistance Program $212,157 - 0
93.110 Maternal and Child Health Federal Consolidated Programs $169,791 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $153,321 - 0
93.394 Cancer Detection and Diagnosis Research $137,063 - 0
93.395 Cancer Treatment Research $119,150 - 0
16.588 Violence Against Women Formula Grants $92,531 - 0
93.889 National Bioterrorism Hospital Preparedness Program $79,500 - 0
93.396 Cancer Biology Research $28,368 - 0
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $21,668 - 0
16.017 Sexual Assault Services Formula Program $18,970 - 0
93.838 Lung Diseases Research $8,719 - 0
93.865 Child Health and Human Development Extramural Research $5,722 - 0
93.837 Cardiovascular Diseases Research $3,875 - 0

Contacts

Name Title Type
JQLMFNLA4BP4 Richard Einwechter Auditee
2125856489 David Wiessel Auditor
No contacts on file

Notes to SEFA

Title: COVID-19 – Provider Relief Fund Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of The New York and Presbyterian Hospital (NYPH) including its direct and indirect subsidiaries and controlled affiliates, which include NewYork-Presbyterian/Hudson Valley (NYP/Hudson Valley), NewYork-Presbyterian/Queens (NYP/Queens) and other consolidated entities as described in Note 1 to the consolidated financial statements in the previous section. The reporting entity resulting from the consolidation of these entities is referred to herein as the “Hospital.” The Schedule 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 applicable requirements, certain programs may be presented on the Schedule in a fiscal period based on the program-specific guidance (see Notes 2, 5 and 6). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the Hospital. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loans and loan guarantees, or other noncash assistance. Pass-through programs received by the Hospital may include, in addition to federal funds, support from other sources. The accompanying Schedule reflects only those expenditures that have been supported by federal funds. Determinations as to the level of federal funding have been made based on communications of funding levels provided by the pass-through agencies. In certain circumstances, the funding levels communicated are estimated and subject to finalization upon the completion of the budget period for the program. 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 for Uniform Guidance awards. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. In accordance with the U.S. Department of Health and Human Services’ requirements specific to Federal Assistance Listing number 93.498, COVID-19 – Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution, the amount presented on the accompanying Schedule for the year ended December 31, 2023 for Federal Assistance Listing number 93.498 relates to (i) PRF payments received from January 1, 2022 through December 31, 2022 (ii) used for PRF-eligible activity from the period January 1, 2020 through December 31, 2023 for expenses or January 1, 2020 through June 30, 2023 for lost revenues. This payment receipt period and the activity periods and the resulting amount presented on the accompanying Schedule for the year ended December 31, 2023 reconciles to the PRF information previously reported to the Health Resources and Services Administration (HRSA) for PRF Reporting Periods 5 and 6. See notes to the SEFA for chart. All distributions received in Reporting Periods 5 and 6 are General Distributions. The lost revenues incurred by the Hospital during the periods of availability for PRF Reporting Periods 5 and 6 (January 1, 2020 through June 30, 2023) are in excess of the cumulative distributions received in PRF Reporting Periods 1 through 4 (which addressed payments received during April 10, 2020 to December 31, 2021, and previously reported on the 2021 and 2022 schedules of expenditures of federal awards in accordance with the guidance specific to Federal Assistance Listing number 93.498) and Periods 5 and 6. Therefore, the amounts presented in the table above and on the accompanying Schedule for the year ended December 31, 2023 are limited to distributions received in PRF Reporting Periods 5 and 6.
Title: Vaccines for Children Program Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of The New York and Presbyterian Hospital (NYPH) including its direct and indirect subsidiaries and controlled affiliates, which include NewYork-Presbyterian/Hudson Valley (NYP/Hudson Valley), NewYork-Presbyterian/Queens (NYP/Queens) and other consolidated entities as described in Note 1 to the consolidated financial statements in the previous section. The reporting entity resulting from the consolidation of these entities is referred to herein as the “Hospital.” The Schedule 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 applicable requirements, certain programs may be presented on the Schedule in a fiscal period based on the program-specific guidance (see Notes 2, 5 and 6). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the Hospital. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loans and loan guarantees, or other noncash assistance. Pass-through programs received by the Hospital may include, in addition to federal funds, support from other sources. The accompanying Schedule reflects only those expenditures that have been supported by federal funds. Determinations as to the level of federal funding have been made based on communications of funding levels provided by the pass-through agencies. In certain circumstances, the funding levels communicated are estimated and subject to finalization upon the completion of the budget period for the program. 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 for Uniform Guidance awards. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. During the year ended December 31, 2023, the Hospital participated in the New York City Department of Health and Mental Hygiene – Vaccines for Children Program through the provision of vaccinations. The U.S. Department of Health and Human Services, the federal agency that sponsors this program under Federal Assistance Listing number 93.268, has determined that the vaccines administered are considered “property in lieu of money” and, therefore, should be reported as federal awards expended by the Hospital for purposes of presentation in the accompanying Schedule.
Title: Food and Nutritional Awards Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of The New York and Presbyterian Hospital (NYPH) including its direct and indirect subsidiaries and controlled affiliates, which include NewYork-Presbyterian/Hudson Valley (NYP/Hudson Valley), NewYork-Presbyterian/Queens (NYP/Queens) and other consolidated entities as described in Note 1 to the consolidated financial statements in the previous section. The reporting entity resulting from the consolidation of these entities is referred to herein as the “Hospital.” The Schedule 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 applicable requirements, certain programs may be presented on the Schedule in a fiscal period based on the program-specific guidance (see Notes 2, 5 and 6). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the Hospital. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loans and loan guarantees, or other noncash assistance. Pass-through programs received by the Hospital may include, in addition to federal funds, support from other sources. The accompanying Schedule reflects only those expenditures that have been supported by federal funds. Determinations as to the level of federal funding have been made based on communications of funding levels provided by the pass-through agencies. In certain circumstances, the funding levels communicated are estimated and subject to finalization upon the completion of the budget period for the program. 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 for Uniform Guidance awards. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. During the year ended December 31, 2023, the Hospital participated in the State of New York Department of Health – Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) through the provision of nutritional counseling and the receipt and distribution of food vouchers. The U.S. Department of Agriculture, the federal agency that sponsors the WIC program under Federal Assistance Listing number 10.557, has determined that WIC food vouchers are considered “property in lieu of money” and, therefore, should be reported as federal awards received by the Hospital for the purpose of presentation in the Schedule. The amount reported in the Schedule for the WIC program under Federal Assistance Listing number 10.557 represents the federally funded value of food vouchers issued ($12,294,136) plus administrative costs ($3,361,094) for the year ended December 31, 2023. In addition to the federal funds received for the WIC program, in 2023 approximately 16.2% of the WIC program’s total administrative and nutritional counseling costs were funded by the State of New York Department of Health; such amounts are excluded from the accompanying Schedule.
Title: U.S. Department of Housing and Urban Development Mortgage Insurance Program Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of The New York and Presbyterian Hospital (NYPH) including its direct and indirect subsidiaries and controlled affiliates, which include NewYork-Presbyterian/Hudson Valley (NYP/Hudson Valley), NewYork-Presbyterian/Queens (NYP/Queens) and other consolidated entities as described in Note 1 to the consolidated financial statements in the previous section. The reporting entity resulting from the consolidation of these entities is referred to herein as the “Hospital.” The Schedule 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 applicable requirements, certain programs may be presented on the Schedule in a fiscal period based on the program-specific guidance (see Notes 2, 5 and 6). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the Hospital. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loans and loan guarantees, or other noncash assistance. Pass-through programs received by the Hospital may include, in addition to federal funds, support from other sources. The accompanying Schedule reflects only those expenditures that have been supported by federal funds. Determinations as to the level of federal funding have been made based on communications of funding levels provided by the pass-through agencies. In certain circumstances, the funding levels communicated are estimated and subject to finalization upon the completion of the budget period for the program. 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 for Uniform Guidance awards. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. Through October 30, 2023, NYPH had a mortgage loan insured under the provisions of the U.S. Department of Housing and Urban Development – Federal Housing Administration (FHA) Section 241 mortgage insurance program. The mortgage insurance program is to be considered a federal award for purposes of compliance with the Uniform Guidance, as determined by the U.S. Department of Housing and Urban Development (HUD). The outstanding balance of the loan is seen in the notes to the SEFA. Pursuant to the mortgage loan agreement, NYPH was, among other compliance requirements, required to maintain certain debt service funds, financial ratios, and to obtain approval from HUD to incur additional debt above specified levels if profitability requirements were not met. The mortgage was collateralized by certain NYPH property, buildings and equipment and gross receipts derived from operations. On August 29, 2023, NYPH closed on the issuance of Dormitory Authority of the State of New York Series 2023 Revenue Bonds. The FHA Section 241 mortgage loan was fully repaid on October 30, 2023 (the Prepayment Date) with the proceeds of the Series 2023A bonds. On the Prepayment Date, the FHA-insured mortgage loan was satisfied and released.
Title: Federal Emergency Management Agency: Disaster Grants Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of The New York and Presbyterian Hospital (NYPH) including its direct and indirect subsidiaries and controlled affiliates, which include NewYork-Presbyterian/Hudson Valley (NYP/Hudson Valley), NewYork-Presbyterian/Queens (NYP/Queens) and other consolidated entities as described in Note 1 to the consolidated financial statements in the previous section. The reporting entity resulting from the consolidation of these entities is referred to herein as the “Hospital.” The Schedule 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 applicable requirements, certain programs may be presented on the Schedule in a fiscal period based on the program-specific guidance (see Notes 2, 5 and 6). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of the Hospital. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loans and loan guarantees, or other noncash assistance. Pass-through programs received by the Hospital may include, in addition to federal funds, support from other sources. The accompanying Schedule reflects only those expenditures that have been supported by federal funds. Determinations as to the level of federal funding have been made based on communications of funding levels provided by the pass-through agencies. In certain circumstances, the funding levels communicated are estimated and subject to finalization upon the completion of the budget period for the program. 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 for Uniform Guidance awards. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. De Minimis Rate Used: N Rate Explanation: The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Hospital did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule. In 2023, NYPH received reimbursement payments under the Federal Emergency Management Agency (FEMA) COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (Federal Assistance Listing number 97.036). In April 2023, NYPH received approximately $174.1 million from the United States Department of Homeland Security (USDHS), the federal agency that sponsors Federal Assistance Listing number 97.036, passed-through the State of New York Division of Homeland Security and Emergency Services (NYSDHSES). The payment received in April 2023, along with other amounts received in 2020 through 2022, relate to project worksheets submitted by NYPH to FEMA since 2020 for funding of eligible costs incurred. The Hospital is finalizing other related project worksheets submitted to FEMA and intends to submit additional applications for funding of eligible costs incurred through the end of the defined period. The ultimate amount of incurred costs that the Hospital may be reimbursed is still uncertain. In January 2023, the Hospital received approximately $93.2 million from the USDHS, passed-through the New York State Department of Health, for eligible employee support costs incurred during the period January 2020 through September 2020. These reimbursements of costs incurred in prior years, totaling approximately $267.4 million, are included in the accompanying Schedule for the year ended December 31, 2023 in accordance with the guidance specific to Federal Assistance Listing number 97.036.

Finding Details

Criteria or specified requirement (including statutory, regulatory, or other citation: 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The 2 CFR section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal awards should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. 2 CFR section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; (d) be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; (e) be determined in accordance with generally accepted accounting principles; (f) not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; (g) be adequately documented; and (h) cost must be incurred during the approved budget period.” Condition: The New York and Presbyterian Hospital (the Hospital) has processes and internal controls in place to ensure costs submitted to the Federal Emergency Management Agency (“FEMA”) in relation to the Disaster Grants – Public Assistance program were eligible under FEMA’s provisions and were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the costs to ensure the costs comply with the terms and conditions of the award. The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. Cause: The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. The difference was due to payment discount provisions utilized in accordance with a previously existing vendor agreement for one specific vendor, resulting in an overstatement of amounts included in the FEMA reimbursement request submitted in the Grants Portal. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. Effect or potential effect: Due to the above, there is a misstatement of the amounts reported in the FEMA reimbursement submission in the Grants Portal resulting in questioned costs of approximately $268,900. Questioned costs: Approximately $268,900, representing the difference between the amounts paid for certain invoices as compared to the amounts incorrectly submitted in the Grants Portal and certain duplicated items. Context: During our testing of FEMA expenditures underlying the grant for FEMA project number 140215, we identified expenditures that were paid at discounted amounts (in accordance with payment terms with a specific vendor) but included in the FEMA reimbursement submission in the Grants Portal at the full invoice amount, without consideration to the discount taken. The invoiced amounts exceeded the actual amounts paid by approximately $84,500. The terms and conditions of the FEMA award require recipients to submit eligible costs incurred limited to the amount paid, thus this issue results in questioned costs. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. The total FEMA expenditures for project number 140215 included on the Hospital’s schedule of expenditures of federal awards is $174.1 million, which includes $16.9 million related to the specific vendor for the payment-related issue described above. The FEMA-obligated amount under this grant is the third obligation for costs that the Hospital submitted to FEMA for reimbursement under this project. The project was initially established through FEMA’s optional expedited funding application and subsequently amended to a streamlined project under FEMA’s provisions; the amendment also extended the grant period beyond the initial ninety-day period of the original application to cover the period through July 1, 2022. The Hospital has adjusted for a portion of the questioned costs in a subsequent claim submission and management has indicated that they will follow this same process for the balance of the questioned cost items. Additionally, management anticipates that any reimbursement revisions, such as for the questioned costs described above, identified related to the third obligated amount will be addressed through the reconciliation of the overall project cost, inclusive of expected payments to the Hospital for additional eligible costs that have been submitted by the Hospital. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should correct the cost summary schedule for this project during the reconciliation of the overall project cost, or address in another manner as directed by FEMA. Additionally, management should continue to review on an ongoing basis for similar costs included in the FEMA reimbursement submission for potential submission errors related to discounted amounts. View of responsible officials: Management agrees with the finding.
Criteria or specified requirement (including statutory, regulatory, or other citation: 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The 2 CFR section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal awards should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. 2 CFR section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; (d) be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; (e) be determined in accordance with generally accepted accounting principles; (f) not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; (g) be adequately documented; and (h) cost must be incurred during the approved budget period.” Condition: The New York and Presbyterian Hospital (the Hospital) has processes and internal controls in place to ensure costs submitted to the Federal Emergency Management Agency (“FEMA”) in relation to the Disaster Grants – Public Assistance program were eligible under FEMA’s provisions and were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the costs to ensure the costs comply with the terms and conditions of the award. The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. Cause: The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. The difference was due to payment discount provisions utilized in accordance with a previously existing vendor agreement for one specific vendor, resulting in an overstatement of amounts included in the FEMA reimbursement request submitted in the Grants Portal. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. Effect or potential effect: Due to the above, there is a misstatement of the amounts reported in the FEMA reimbursement submission in the Grants Portal resulting in questioned costs of approximately $268,900. Questioned costs: Approximately $268,900, representing the difference between the amounts paid for certain invoices as compared to the amounts incorrectly submitted in the Grants Portal and certain duplicated items. Context: During our testing of FEMA expenditures underlying the grant for FEMA project number 140215, we identified expenditures that were paid at discounted amounts (in accordance with payment terms with a specific vendor) but included in the FEMA reimbursement submission in the Grants Portal at the full invoice amount, without consideration to the discount taken. The invoiced amounts exceeded the actual amounts paid by approximately $84,500. The terms and conditions of the FEMA award require recipients to submit eligible costs incurred limited to the amount paid, thus this issue results in questioned costs. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. The total FEMA expenditures for project number 140215 included on the Hospital’s schedule of expenditures of federal awards is $174.1 million, which includes $16.9 million related to the specific vendor for the payment-related issue described above. The FEMA-obligated amount under this grant is the third obligation for costs that the Hospital submitted to FEMA for reimbursement under this project. The project was initially established through FEMA’s optional expedited funding application and subsequently amended to a streamlined project under FEMA’s provisions; the amendment also extended the grant period beyond the initial ninety-day period of the original application to cover the period through July 1, 2022. The Hospital has adjusted for a portion of the questioned costs in a subsequent claim submission and management has indicated that they will follow this same process for the balance of the questioned cost items. Additionally, management anticipates that any reimbursement revisions, such as for the questioned costs described above, identified related to the third obligated amount will be addressed through the reconciliation of the overall project cost, inclusive of expected payments to the Hospital for additional eligible costs that have been submitted by the Hospital. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should correct the cost summary schedule for this project during the reconciliation of the overall project cost, or address in another manner as directed by FEMA. Additionally, management should continue to review on an ongoing basis for similar costs included in the FEMA reimbursement submission for potential submission errors related to discounted amounts. View of responsible officials: Management agrees with the finding.