Assistance Listing Number, Federal Agency, and Program Name - 93.498, Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution
Federal Award Identification Number and Year - N/A
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - According to the Post Payment Notice of Reporting Requirements issued by the U.S. Department of Health and Human Services (HHS) dated October 7, 2022, the reporting entity must report on expenses paid for with payments received through the general and targeted distribution payments. Such expenses must be those that another source has not reimbursed and is not obligated to reimburse. HRSA considers unreimbursed expenses attributable to COVID-19 first in the overall use of funds calculation.
Condition - WakeMed reported duplicate expenditures within the Period 2 portal submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - None
Context - WakeMed entered expenditures totaling $941,790 into the Period 1 portal submission. WakeMed then reported the same expenditures into the Period 2 portal submission.
Cause and Effect - Management misunderstood the functionality of the reporting portal site and reported the same expenses from Period 1 into the Period 2 portal submission. The duplicate expenses reported in Period 2 were improperly applied against Period 2 funding received, and, as a result, lost revenue used in determining the total Provider Relief Funds earned were improperly calculated.
Recommendation - Management should review all reporting requirements for the grant prior to submission of required reports.
Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. WakeMed reviewed the portal submission to determine the impact of the error on the amount of Provider Relief Funds recognized and reported on the SEFA. WakeMed has concluded that there was carried forward lost revenue of $26.4 million that is eligible to be applied to the Period 2 funds of $10.9 million. Therefore, there is no impact on the amounts reported on the SEFA. WakeMed has implemented additional review procedures for grant report submissions to ensure the accuracy of the reports in accordance with granting agency’s reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - 93.461, Department of Health and Human Services, COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund
Federal Award Identification Number and Year - N/A
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - Yes
Prior year finding number: 2021-001
Criteria - The COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund grant is to be used for "reimbursement of payment for COVID-19 testing and testing related items for individuals who do not have coverage through an individual or employer sponsored plan," per the 2022 Compliance Supplement.
Condition - WakeMed charged costs associated with ineligible individuals to the grant.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During testing of 60 patients, we identified 1 patient who should not have been submitted to HRSA for reimbursement, as they were covered by insurance and, therefore, ineligible. The ineligible cost was removed from the SEFA and is in the process of being refunded to HRSA.
Cause and Effect - While WakeMed had a process in place to review individuals for eligibility prior to claims being submitted, there was no process to subsequently evaluate changes in insurance status that may result in the patient being ineligible for the program.
Recommendation - WakeMed should have a process in place to review and identify claims in which insurance status may have changed, in which refunds need to be issued to HRSA.
Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding as reported. WakeMed identified all HRSA patients with other documented insurance within the system. Each claim was reviewed to identify patients with active insurance coverage. Patients identified with active insurance coverage were considered ineligible for grant purposes, and the HRSA payments are in the process of being refunded. These costs were removed from the SEFA. In addition, WakeMed has written off all outstanding HRSA claims.
Assistance Listing Number, Federal Agency, and Program Name - 21.027 U.S. Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - YDYNCVFA9NH4
Pass through Entity - City of Raleigh, North Carolina
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.508(b), an auditee must prepare appropriate financial statements, including the schedule of expenditures of federal awards, in accordance with 200.510 financial statements. Per 2 CFR 200.510(b), the auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with 200.502 basis for determining federal awards expended.
Condition - Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate.
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - WakeMed did not initially include the funds received through the U.S. Department of the Treasury American Rescue Plan Act of 2021, Coronavirus State and Local Fiscal Recovery Funds on the SEFA.
Cause and Effect - WakeMed did not have a process in place to identify all potential sources of federal funding received during the year, resulting in the SEFA being incomplete for the year ended September 30, 2022. Upon discovery of the error, WakeMed prepared a SEFA that included the U.S. Department of the Treasury American Rescue Plan Act of 2021, Coronavirus State and Local Fiscal Recovery Funds. This lack of controls resulted in the reissuance of the 2022 single audit.
Recommendation - Management should implement controls to ensure all federal funding received is properly identified as such and included on the SEFA.
Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. The federal funding was not received until fiscal year 2023 while some expenditures were incurred in fiscal year 2022. The timing of events contributed to the oversight on the 2022 SEFA. WakeMed has reeducated staff on the preparation of the SEFA in order to prevent this error from reoccurring.
Assistance Listing Number, Federal Agency, and Program Name - 21.027 U.S. Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - YDYNCVFA9NH4
Pass through Entity - City of Raleigh, North Carolina
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 2 CFR 200.318 requires that a nonfederal entity that acquires property or services under a federal award or subaward is required to adopt, maintain, and follow written procurement procedures, which comply with sections 2 CFR 200.318 through 327.
Condition - WakeMed does not have a written policy in place over procurement methods, which covers 2 CFR 200.318 200.327, nor did WakeMed follow required procurement guidelines.
Questioned Costs - $1,010,233
Identification of How Questioned Costs Were Computed - Questioned costs reflect the entire amount of costs expended under the grant during 2022.
Context - WakeMed did not have a written policy in place over procurement methods, which covers 2 CFR 200.318 200.327, when the grant was awarded. In addition, WakeMed did not follow required procurement procedures related to expenditures under the grant, including a competitive bid process for costs charged to the grant as WakeMed entered into the construction contract prior to being awarded the funds.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including procurement provisions, where controls were not in place to identify the requirement to have a written procurement policy and follow 2 CFR 200.318 200.327.
Recommendation - WakeMed should develop a written procurement policy, which complies with the 2 CFR 200.318 200.327 sections, and ensure controls are in place to comply with the procurement policy on an ongoing basis.
Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. WakeMed is in the process of updating their existing procurement policy to include the relevant sections from the Code of Federal Regulations and will provide education to the areas involved in procurement and use of federal funds on these requirements.
Assistance Listing Number, Federal Agency, and Program Name - 93.498, Department of Health and Human Services, Provider Relief Fund and American Rescue Plan Rural Distribution
Federal Award Identification Number and Year - N/A
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - According to the Post Payment Notice of Reporting Requirements issued by the U.S. Department of Health and Human Services (HHS) dated October 7, 2022, the reporting entity must report on expenses paid for with payments received through the general and targeted distribution payments. Such expenses must be those that another source has not reimbursed and is not obligated to reimburse. HRSA considers unreimbursed expenses attributable to COVID-19 first in the overall use of funds calculation.
Condition - WakeMed reported duplicate expenditures within the Period 2 portal submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - None
Context - WakeMed entered expenditures totaling $941,790 into the Period 1 portal submission. WakeMed then reported the same expenditures into the Period 2 portal submission.
Cause and Effect - Management misunderstood the functionality of the reporting portal site and reported the same expenses from Period 1 into the Period 2 portal submission. The duplicate expenses reported in Period 2 were improperly applied against Period 2 funding received, and, as a result, lost revenue used in determining the total Provider Relief Funds earned were improperly calculated.
Recommendation - Management should review all reporting requirements for the grant prior to submission of required reports.
Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. WakeMed reviewed the portal submission to determine the impact of the error on the amount of Provider Relief Funds recognized and reported on the SEFA. WakeMed has concluded that there was carried forward lost revenue of $26.4 million that is eligible to be applied to the Period 2 funds of $10.9 million. Therefore, there is no impact on the amounts reported on the SEFA. WakeMed has implemented additional review procedures for grant report submissions to ensure the accuracy of the reports in accordance with granting agency’s reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - 93.461, Department of Health and Human Services, COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund
Federal Award Identification Number and Year - N/A
Pass through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - Yes
Prior year finding number: 2021-001
Criteria - The COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund grant is to be used for "reimbursement of payment for COVID-19 testing and testing related items for individuals who do not have coverage through an individual or employer sponsored plan," per the 2022 Compliance Supplement.
Condition - WakeMed charged costs associated with ineligible individuals to the grant.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During testing of 60 patients, we identified 1 patient who should not have been submitted to HRSA for reimbursement, as they were covered by insurance and, therefore, ineligible. The ineligible cost was removed from the SEFA and is in the process of being refunded to HRSA.
Cause and Effect - While WakeMed had a process in place to review individuals for eligibility prior to claims being submitted, there was no process to subsequently evaluate changes in insurance status that may result in the patient being ineligible for the program.
Recommendation - WakeMed should have a process in place to review and identify claims in which insurance status may have changed, in which refunds need to be issued to HRSA.
Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding as reported. WakeMed identified all HRSA patients with other documented insurance within the system. Each claim was reviewed to identify patients with active insurance coverage. Patients identified with active insurance coverage were considered ineligible for grant purposes, and the HRSA payments are in the process of being refunded. These costs were removed from the SEFA. In addition, WakeMed has written off all outstanding HRSA claims.
Assistance Listing Number, Federal Agency, and Program Name - 21.027 U.S. Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - YDYNCVFA9NH4
Pass through Entity - City of Raleigh, North Carolina
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.508(b), an auditee must prepare appropriate financial statements, including the schedule of expenditures of federal awards, in accordance with 200.510 financial statements. Per 2 CFR 200.510(b), the auditee must also prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements, which must include the total federal awards expended, as determined in accordance with 200.502 basis for determining federal awards expended.
Condition - Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate.
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - WakeMed did not initially include the funds received through the U.S. Department of the Treasury American Rescue Plan Act of 2021, Coronavirus State and Local Fiscal Recovery Funds on the SEFA.
Cause and Effect - WakeMed did not have a process in place to identify all potential sources of federal funding received during the year, resulting in the SEFA being incomplete for the year ended September 30, 2022. Upon discovery of the error, WakeMed prepared a SEFA that included the U.S. Department of the Treasury American Rescue Plan Act of 2021, Coronavirus State and Local Fiscal Recovery Funds. This lack of controls resulted in the reissuance of the 2022 single audit.
Recommendation - Management should implement controls to ensure all federal funding received is properly identified as such and included on the SEFA.
Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. The federal funding was not received until fiscal year 2023 while some expenditures were incurred in fiscal year 2022. The timing of events contributed to the oversight on the 2022 SEFA. WakeMed has reeducated staff on the preparation of the SEFA in order to prevent this error from reoccurring.
Assistance Listing Number, Federal Agency, and Program Name - 21.027 U.S. Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - YDYNCVFA9NH4
Pass through Entity - City of Raleigh, North Carolina
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 2 CFR 200.318 requires that a nonfederal entity that acquires property or services under a federal award or subaward is required to adopt, maintain, and follow written procurement procedures, which comply with sections 2 CFR 200.318 through 327.
Condition - WakeMed does not have a written policy in place over procurement methods, which covers 2 CFR 200.318 200.327, nor did WakeMed follow required procurement guidelines.
Questioned Costs - $1,010,233
Identification of How Questioned Costs Were Computed - Questioned costs reflect the entire amount of costs expended under the grant during 2022.
Context - WakeMed did not have a written policy in place over procurement methods, which covers 2 CFR 200.318 200.327, when the grant was awarded. In addition, WakeMed did not follow required procurement procedures related to expenditures under the grant, including a competitive bid process for costs charged to the grant as WakeMed entered into the construction contract prior to being awarded the funds.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including procurement provisions, where controls were not in place to identify the requirement to have a written procurement policy and follow 2 CFR 200.318 200.327.
Recommendation - WakeMed should develop a written procurement policy, which complies with the 2 CFR 200.318 200.327 sections, and ensure controls are in place to comply with the procurement policy on an ongoing basis.
Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding as reported. WakeMed is in the process of updating their existing procurement policy to include the relevant sections from the Code of Federal Regulations and will provide education to the areas involved in procurement and use of federal funds on these requirements.