Audit 341752

Assistance Listing Number: 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not applicable Award Number / Year: N/A / 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition/Context: The Center reported $659,718 of total other PRF expenses incurred in the period 2 submission which were categorized as Mortgage/Rent. However, the expenses incurred in this category were not determined to be eligible expenses under the terms and conditions of 2 CFR 200.303(a). The Center also submitted the period 2 report past the reporting deadline. Effect: The amounts reported to Health Resources & Services Administration (HRSA) did not have the necessary supporting documentation that was used to prepare and submit the initial reporting. Questioned Costs: None Cause: The Center misinterpreted the definitions of eligible expenses that should be included in the submission. Recommendation: We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood, and that information used in preparation of the reports are reviewed, with errors addressed and maintained prior to reporting. Management’s Response: Management agrees with the finding and has subsequently supported other eligible expenses that were not included in the original submission. These amounts exceeded the funding received.

Assistance Listing Number: 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural DistributionFederal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not applicableAward Number / Year: N/A / 2022 Compliance Requirements: Activities Allowed or Unallowed/ Allowable Costs Criteria: As outlined in Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623, funds are appropriated to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. That funds appropriated under this paragraph in this Act shall be available for building or construction of temporary structures, leasing of properties, medical supplies and equipment, including personal protective equipment and testing supplies, increased workforce and trainings, emergency operation centers, retrofitting facilities and surge capacity. Uniform Guidance requires that charges to federal awards must be based on records that are supported by a system of internal controls that provide reasonable assurance about the accuracy, allowability and proper allocation of the charges. Condition and Context: During our testing, we noted that 22 expenditure samples out of 40 tested for covid related expenses were supported by invoices that were for allowable expenses, but there was no evidence of review and approval by an appropriate individual for proper authorization of payment. This was not a statistically valid sample.Effect: Although the underlying expenses are allowable expenditures under the provider relief program, the support was not maintained to document to approval as required by Uniform Guidance, therefore this is considered a significant deficiency in internal controls.Questioned Cost: None Cause: The Center does not have an adequate polices and systems needed to implement a properly designed system of controls over these significant transaction cycles. Recommendation: Policies and procedures related to review and approval around disbursements should be assessed to determine whether additional review procedures or further segregation of duties are feasible.Management’s Response: Management agrees with the finding. While we have policies and procedures as recommended by the auditors, there is an opportunity to review our policies and procedures related to the review and approval around disbursements. Through the leadership of our Chief Financial Officer and our Director of Finance, our internal control policies and procedures will be evaluated and as needed, amended, with an effective date no later than June 30, 2025.

Assistance Listing Number: 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not applicable Award Number / Year: N/A / 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition/Context: The Center reported $659,718 of total other PRF expenses incurred in the period 2 submission which were categorized as Mortgage/Rent. However, the expenses incurred in this category were not determined to be eligible expenses under the terms and conditions of 2 CFR 200.303(a). The Center also submitted the period 2 report past the reporting deadline. Effect: The amounts reported to Health Resources & Services Administration (HRSA) did not have the necessary supporting documentation that was used to prepare and submit the initial reporting. Questioned Costs: None Cause: The Center misinterpreted the definitions of eligible expenses that should be included in the submission. Recommendation: We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood, and that information used in preparation of the reports are reviewed, with errors addressed and maintained prior to reporting. Management’s Response: Management agrees with the finding and has subsequently supported other eligible expenses that were not included in the original submission. These amounts exceeded the funding received.

Assistance Listing Number: 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural DistributionFederal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not applicableAward Number / Year: N/A / 2022 Compliance Requirements: Activities Allowed or Unallowed/ Allowable Costs Criteria: As outlined in Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623, funds are appropriated to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. That funds appropriated under this paragraph in this Act shall be available for building or construction of temporary structures, leasing of properties, medical supplies and equipment, including personal protective equipment and testing supplies, increased workforce and trainings, emergency operation centers, retrofitting facilities and surge capacity. Uniform Guidance requires that charges to federal awards must be based on records that are supported by a system of internal controls that provide reasonable assurance about the accuracy, allowability and proper allocation of the charges. Condition and Context: During our testing, we noted that 22 expenditure samples out of 40 tested for covid related expenses were supported by invoices that were for allowable expenses, but there was no evidence of review and approval by an appropriate individual for proper authorization of payment. This was not a statistically valid sample.Effect: Although the underlying expenses are allowable expenditures under the provider relief program, the support was not maintained to document to approval as required by Uniform Guidance, therefore this is considered a significant deficiency in internal controls.Questioned Cost: None Cause: The Center does not have an adequate polices and systems needed to implement a properly designed system of controls over these significant transaction cycles. Recommendation: Policies and procedures related to review and approval around disbursements should be assessed to determine whether additional review procedures or further segregation of duties are feasible.Management’s Response: Management agrees with the finding. While we have policies and procedures as recommended by the auditors, there is an opportunity to review our policies and procedures related to the review and approval around disbursements. Through the leadership of our Chief Financial Officer and our Director of Finance, our internal control policies and procedures will be evaluated and as needed, amended, with an effective date no later than June 30, 2025.