Audit 329516

FY End
2022-06-30
Total Expended
$4.23M
Findings
4
Programs
1
Organization: Concepts of Independence, Inc. (NY)
Year: 2022 Accepted: 2024-11-22

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
509782 2022-001 - - L
509783 2022-002 - - A
1086224 2022-001 - - L
1086225 2022-002 - - A

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $4.23M Yes 2

Contacts

Name Title Type
YBL2XTMBPNV6 Anthony Caputo Auditee
2122933999 Yossi Messafi Auditor
No contacts on file

Notes to SEFA

Title: General Accounting Policies: 2. Summary of Significant Accounting Policies Basis of Presentation The accompanying Schedule of Expenditures of Federal Awards (the “schedule”) is prepared in accordance with accounting principles generally accepted in the United States of America. 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”). Because the schedule presents only a selected portion of the Organization's other revenue, it is not intended to and does not present the financial position, changes in equity, or cash flows of the Organization. Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution – Assistance Listing Number 93.498 For the HHS awards related to the COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“PRF”) program, HHS has indicated the amounts on the schedule be reported corresponding to reporting requirements of the HRSA 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 includes $4,233,758 received from HHS between July 1, 2020 to December 31, 2020. In accordance with guidance from HHS, these amounts are presented as Period 2. Such amounts were recognized as other income in the Organization’s financial statements for the year ended June 30, 2021. Estimates The preparation of the schedule in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amount in other revenue during the reporting period. Actual results could differ from those estimates. Subsequent Events The schedule and related disclosures include evaluation of events through November 13, 2024, which is the date the schedule was available to be issued. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Concepts of Independence, Inc. (the "Organization"), a not-for-profit home care service agency, was established to provide Consumer Directed Personal Assistance Program services to individuals in New York State. Federal funds were received in awards from the U.S. Department of Health and Human Services (HHS), including through federal programs established by legislation issued in response to the COVID-19 pandemic (e.g., Coronavirus Aid, Relief, and Economic Security (CARES) Act or the American Rescue Plan (ARP)).
Title: Compliance Accounting Policies: 2. Summary of Significant Accounting Policies Basis of Presentation The accompanying Schedule of Expenditures of Federal Awards (the “schedule”) is prepared in accordance with accounting principles generally accepted in the United States of America. 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”). Because the schedule presents only a selected portion of the Organization's other revenue, it is not intended to and does not present the financial position, changes in equity, or cash flows of the Organization. Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution – Assistance Listing Number 93.498 For the HHS awards related to the COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“PRF”) program, HHS has indicated the amounts on the schedule be reported corresponding to reporting requirements of the HRSA 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 includes $4,233,758 received from HHS between July 1, 2020 to December 31, 2020. In accordance with guidance from HHS, these amounts are presented as Period 2. Such amounts were recognized as other income in the Organization’s financial statements for the year ended June 30, 2021. Estimates The preparation of the schedule in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amount in other revenue during the reporting period. Actual results could differ from those estimates. Subsequent Events The schedule and related disclosures include evaluation of events through November 13, 2024, which is the date the schedule was available to be issued. De Minimis Rate Used: N Rate Explanation: The Organization has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The rules and regulations governing the COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“PRF”) program (the “program”) have continued to evolve since the program’s inception in March 2020. Management believes that the Organization is in compliance with the program’s rules and regulations other than compliance matters noted in the schedule of findings and questioned costs. However, the program’s rules and regulations are complex and subject to interpretation, and compliance may be subject to further government review.

Finding Details

Finding 2022-001: Late Submission of Single Audit Report Criteria: According to 2 CFR 200.512(a), the Single Audit report must be submitted within nine months after the end of the fiscal year. Condition: The Single Audit report for the fiscal year ended June 30, 2022, was not submitted on or prior to March 31, 2023, which was the nine-month deadline for report submission. Cause: The delay was due to management being unaware of the single audit submission requirements since management had not received funds requiring submission of a single audit in previous years. Effect: The late submission constitutes non-compliance with federal audit requirements, which may affect the Organization’s eligibility for future federal funding and could result in penalties or increased scrutiny from federal agencies. Questioned Costs: None Repeat Finding: No Recommendation: It is recommended that the Organization: 1. Strengthen its internal controls to ensure timely completion and submission of the Single Audit report. 2. Implement a monitoring system to track audit progress and deadlines. View of Responsible Official: See Corrective Action Plan
Finding 2022-002: Revenue reported in PRF submission was overstated for 2nd quarter in 2019 and 2020 Criteria: HRSA requires entities to report quarterly net patient revenue under the PRF reporting requirements that is net of adjustments for all third-party payers, charity care adjustments, bad debt, and any discounts or adjustments. Condition: Management’s submission reported revenues for the second quarter of 2019 and the second quarter of 2020 gross of adjustments for bad debt. Cause: Management was unaware of the requirement to report net patient revenue net of adjustments. Effect: Amount reported for the 2nd quarter of 2019 and the 2nd quarter of 2022 were overstated resulting in lost revenues that were higher than actual. This had no effect on lost revenue recovered by the Organization since the corrected lost revenue remained higher than the amount provided by the PRF program Questioned Costs: None Repeat Finding: No Recommendation: We recommend that management become familiar with all PRF reporting requirements should additional funds become available. View of Responsible Official: See Corrective Action Plan
Finding 2022-001: Late Submission of Single Audit Report Criteria: According to 2 CFR 200.512(a), the Single Audit report must be submitted within nine months after the end of the fiscal year. Condition: The Single Audit report for the fiscal year ended June 30, 2022, was not submitted on or prior to March 31, 2023, which was the nine-month deadline for report submission. Cause: The delay was due to management being unaware of the single audit submission requirements since management had not received funds requiring submission of a single audit in previous years. Effect: The late submission constitutes non-compliance with federal audit requirements, which may affect the Organization’s eligibility for future federal funding and could result in penalties or increased scrutiny from federal agencies. Questioned Costs: None Repeat Finding: No Recommendation: It is recommended that the Organization: 1. Strengthen its internal controls to ensure timely completion and submission of the Single Audit report. 2. Implement a monitoring system to track audit progress and deadlines. View of Responsible Official: See Corrective Action Plan
Finding 2022-002: Revenue reported in PRF submission was overstated for 2nd quarter in 2019 and 2020 Criteria: HRSA requires entities to report quarterly net patient revenue under the PRF reporting requirements that is net of adjustments for all third-party payers, charity care adjustments, bad debt, and any discounts or adjustments. Condition: Management’s submission reported revenues for the second quarter of 2019 and the second quarter of 2020 gross of adjustments for bad debt. Cause: Management was unaware of the requirement to report net patient revenue net of adjustments. Effect: Amount reported for the 2nd quarter of 2019 and the 2nd quarter of 2022 were overstated resulting in lost revenues that were higher than actual. This had no effect on lost revenue recovered by the Organization since the corrected lost revenue remained higher than the amount provided by the PRF program Questioned Costs: None Repeat Finding: No Recommendation: We recommend that management become familiar with all PRF reporting requirements should additional funds become available. View of Responsible Official: See Corrective Action Plan