2022-001: Accuracy of PRF Reporting Grantor: Department of Health and Human Services Program Name: Provider Relief Fund Federal Award Year: October 1, 2021 through September 30, 2022 Federal Award Number: Not available Assistance Listing Number: 93.498 Criteria or Requirement PRF recipients that received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report on several required data elements as part of the post-payment reporting process. Reporting must be completed and submitted to HRSA by the reporting dates specified by HRSA. Additionally, Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section 03(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls 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 (COSO). Condition Found, Including Perspective The dollar amount of expenses reported by management in the Health Resources and Services Administration (HRSA) portal Period 2 submission ($5,947,568) was incorrect. Management entered the total dollar amounts of expenses for Periods 1 and 2 rather than just the Period 2 expenses that should have been reported in the Period 2 submission. Period 2 expenses should have been $884,911. Possible Cause The condition found results from a misinterpretation of the PRF Reporting Period 2 submission. In completing the PRF Reporting Period 2, the HRSA website automatically populated certain PRF Reporting Period 1 data into the HRSA Reporting Period 2 portal. Management interpreted this to mean that unreimbursed COVID expenses are to be reported on a cumulative basis in the PRF Reporting Period 2 and therefore overstated unreimbursed expenses for Period 1. Effect Failure to ensure accuracy of amounts reported in the portal may result in HRSA relying on incomplete or inaccurate information associated to the Institute?s utilization of PRF funds. Questioned Costs None Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding from the Prior Year No. Recommendation We recommend the Institute enhance its internal controls over PRF reporting to ensure each of the data elements reported to HRSA are accurate and result in amounts consistent with its underlying records. Views of Responsible Officials There was an error in PRF Reporting Period 2 due to a misinterpretation of the instructions, which resulted in the double counting of Period 1 expenses. When it was determined there was an error, the Institute immediately contacted HRSA to request re-opening of the Period 2 report to revise the reported expenses. HRSA did not allow for the re-opening of the reporting period and maintained that the adjustment should be submitted during the Institute?s next reporting period. The Institute will make the adjustment in its next reporting period, Period 5, due by September 2023. The adjustment will net down Period 1 expenses and remedy the double counting issue. As the correct interpretation of the instructions is now known to the Institute, the expenses will be reported to HRSA accurately and consistent with the Institute records moving forward.
2022-001: Accuracy of PRF Reporting Grantor: Department of Health and Human Services Program Name: Provider Relief Fund Federal Award Year: October 1, 2021 through September 30, 2022 Federal Award Number: Not available Assistance Listing Number: 93.498 Criteria or Requirement PRF recipients that received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report on several required data elements as part of the post-payment reporting process. Reporting must be completed and submitted to HRSA by the reporting dates specified by HRSA. Additionally, Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section 03(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls 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 (COSO). Condition Found, Including Perspective The dollar amount of expenses reported by management in the Health Resources and Services Administration (HRSA) portal Period 2 submission ($5,947,568) was incorrect. Management entered the total dollar amounts of expenses for Periods 1 and 2 rather than just the Period 2 expenses that should have been reported in the Period 2 submission. Period 2 expenses should have been $884,911. Possible Cause The condition found results from a misinterpretation of the PRF Reporting Period 2 submission. In completing the PRF Reporting Period 2, the HRSA website automatically populated certain PRF Reporting Period 1 data into the HRSA Reporting Period 2 portal. Management interpreted this to mean that unreimbursed COVID expenses are to be reported on a cumulative basis in the PRF Reporting Period 2 and therefore overstated unreimbursed expenses for Period 1. Effect Failure to ensure accuracy of amounts reported in the portal may result in HRSA relying on incomplete or inaccurate information associated to the Institute?s utilization of PRF funds. Questioned Costs None Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding from the Prior Year No. Recommendation We recommend the Institute enhance its internal controls over PRF reporting to ensure each of the data elements reported to HRSA are accurate and result in amounts consistent with its underlying records. Views of Responsible Officials There was an error in PRF Reporting Period 2 due to a misinterpretation of the instructions, which resulted in the double counting of Period 1 expenses. When it was determined there was an error, the Institute immediately contacted HRSA to request re-opening of the Period 2 report to revise the reported expenses. HRSA did not allow for the re-opening of the reporting period and maintained that the adjustment should be submitted during the Institute?s next reporting period. The Institute will make the adjustment in its next reporting period, Period 5, due by September 2023. The adjustment will net down Period 1 expenses and remedy the double counting issue. As the correct interpretation of the instructions is now known to the Institute, the expenses will be reported to HRSA accurately and consistent with the Institute records moving forward.