Assistance Listing Number, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan Rural Distribution
Finding Type Material weakness
Repeat Finding Yes
Prior year finding number 2021 003
Criteria According to 2 CFR § 200.303, HealthSource must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition HealthSource does not have a review process in place related to the lost revenue calculation input into the required reporting submissions to the U.S. Department of Health and Human Services for the Provider Relief Fund program. HeathSource also did not have a review process in place for the required submissions.
Questioned Costs None
Context There was no independent review completed on the lost revenue calculation or the reporting submission to evaluate the completeness and accuracy of the submission.
Cause and Effect The lack of an independent review of the lost revenue calculation and the reporting submission could result in an increased risk of incomplete or inaccurate information included in the reporting submission.
Recommendation HealthSource should implement a process to ensure an independent review of the reporting submission and the documents used to input information into the reporting submission, such as the lost revenue calculation, is completed prior to finalization.
Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and will implement a process to ensure an independent review of the reporting submission and its supporting documents is completed prior to finalization.
Assistance Listing Number, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan Rural Distribution
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
Prior year finding number 2021 004
Criteria Per the Provider Relief Fund, General and Targeted Distribution Post Payment Norice of Reporting Requirements, dated June 11, 2021, expenses that are paid for with General and Targeted PRF payments must be those that are unreimbursed by other sources and that other sources are not obligated to reimburse. Additionally, recipients may choose to apply PRF payments toward lost revenue using one of three options, up to the amount:
Option i: of the difference between actual patient care revenue;
Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenue; or
Option iii: calculated by any reasonable method of estimating revenue.
Condition HealthSource's controls in place for reporting submissions did not identify that guidelines were not followed related to the lost revenue calculations.
Questioned Costs None
Context The reporting submission for lost revenue did not follow the acceptable options provided by the Department of Health and Human Services. Recipients may choose to apply Provider Relief Fund payments toward lost revenue using one of three options: (i) up to the amount of the difference between actual patient care revenue, (ii) up to the amount of the difference between budgeted (if approved prior to March 27, 2020) and actual patient care revenue, or (iii) up to the amount calculated by any reasonable method of estimating revenue. HealthSource used option ii to calculate lost revenue but reported an incorrect total of budgeted and actual revenue in one of the quarters included in the submission. If HealthSource had reported the accurate actual and budgeted revenue amount, it would still have qualified to recognize all PRF payments received. Additionally, the budgeted amounts used in the submission for all quarters of 2021 and 2022 were not approved by March 27, 2020; therefore, option ii was not allowable. HealthSource should have used option iii to report lost revenue.
Cause and Effect Appropriate review of the reporting submission was not completed to ensure the report followed the required guidelines. As a result, the report submitted was inaccurate.
Recommendation We recommend HealthSource implement controls, including levels of review, to ensure reports are completed and submitted in accordance with guidelines established by HHS.
Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and all future submissions will be reviewed by the chief executive officer and the president for accuracy and thoroughness prior to submission upload.
Assistance Listing Number, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan Rural Distribution
Finding Type Material weakness
Repeat Finding Yes
Prior year finding number 2021 003
Criteria According to 2 CFR § 200.303, HealthSource must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition HealthSource does not have a review process in place related to the lost revenue calculation input into the required reporting submissions to the U.S. Department of Health and Human Services for the Provider Relief Fund program. HeathSource also did not have a review process in place for the required submissions.
Questioned Costs None
Context There was no independent review completed on the lost revenue calculation or the reporting submission to evaluate the completeness and accuracy of the submission.
Cause and Effect The lack of an independent review of the lost revenue calculation and the reporting submission could result in an increased risk of incomplete or inaccurate information included in the reporting submission.
Recommendation HealthSource should implement a process to ensure an independent review of the reporting submission and the documents used to input information into the reporting submission, such as the lost revenue calculation, is completed prior to finalization.
Views of Responsible Officials and Corrective Action Plan Management agrees with the finding and will implement a process to ensure an independent review of the reporting submission and its supporting documents is completed prior to finalization.
Assistance Listing Number, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan Rural Distribution
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
Prior year finding number 2021 004
Criteria Per the Provider Relief Fund, General and Targeted Distribution Post Payment Norice of Reporting Requirements, dated June 11, 2021, expenses that are paid for with General and Targeted PRF payments must be those that are unreimbursed by other sources and that other sources are not obligated to reimburse. Additionally, recipients may choose to apply PRF payments toward lost revenue using one of three options, up to the amount:
Option i: of the difference between actual patient care revenue;
Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenue; or
Option iii: calculated by any reasonable method of estimating revenue.
Condition HealthSource's controls in place for reporting submissions did not identify that guidelines were not followed related to the lost revenue calculations.
Questioned Costs None
Context The reporting submission for lost revenue did not follow the acceptable options provided by the Department of Health and Human Services. Recipients may choose to apply Provider Relief Fund payments toward lost revenue using one of three options: (i) up to the amount of the difference between actual patient care revenue, (ii) up to the amount of the difference between budgeted (if approved prior to March 27, 2020) and actual patient care revenue, or (iii) up to the amount calculated by any reasonable method of estimating revenue. HealthSource used option ii to calculate lost revenue but reported an incorrect total of budgeted and actual revenue in one of the quarters included in the submission. If HealthSource had reported the accurate actual and budgeted revenue amount, it would still have qualified to recognize all PRF payments received. Additionally, the budgeted amounts used in the submission for all quarters of 2021 and 2022 were not approved by March 27, 2020; therefore, option ii was not allowable. HealthSource should have used option iii to report lost revenue.
Cause and Effect Appropriate review of the reporting submission was not completed to ensure the report followed the required guidelines. As a result, the report submitted was inaccurate.
Recommendation We recommend HealthSource implement controls, including levels of review, to ensure reports are completed and submitted in accordance with guidelines established by HHS.
Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and all future submissions will be reviewed by the chief executive officer and the president for accuracy and thoroughness prior to submission upload.