Audit 351060

FY End
2023-06-30
Total Expended
$19.67M
Findings
6
Programs
8
Year: 2023 Accepted: 2025-03-31
Auditor: Ernst and Young

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
544400 2023-001 Material Weakness Yes P
544401 2023-002 Material Weakness Yes L
544402 2023-001 Material Weakness - P
1120842 2023-001 Material Weakness Yes P
1120843 2023-002 Material Weakness Yes L
1120844 2023-001 Material Weakness - P

Contacts

Name Title Type
EXF8T7C77MB3 Min Cummings Auditee
7036298155 Amber Brosius Auditor
No contacts on file

Notes to SEFA

Title: 1. Basis of Presentation Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes all federal grants to Virginia Commonwealth University Health System Authority (the Authority) that had federal expenditure activity for the year ended June 30, 2023. The accompanying Schedule is presented using the accrual basis of accounting and in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with the applicable requirements, certain programs may be presented in a fiscal period based on program-specific guidance (Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements of the Authority. 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 amounts reported in the Schedule during the reporting period. Actual results could differ from those estimates. For the year ended June 30, 2023, there were no expenditures passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The Authority has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes all federal grants to Virginia Commonwealth University Health System Authority (the Authority) that had federal expenditure activity for the year ended June 30, 2023. The accompanying Schedule is presented using the accrual basis of accounting and in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with the applicable requirements, certain programs may be presented in a fiscal period based on program-specific guidance (Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements of the Authority. 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 amounts reported in the Schedule during the reporting period. Actual results could differ from those estimates. For the year ended June 30, 2023, there were no expenditures passed through to subrecipients.
Title: 2. Indirect Cost Rate Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes all federal grants to Virginia Commonwealth University Health System Authority (the Authority) that had federal expenditure activity for the year ended June 30, 2023. The accompanying Schedule is presented using the accrual basis of accounting and in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with the applicable requirements, certain programs may be presented in a fiscal period based on program-specific guidance (Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements of the Authority. 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 amounts reported in the Schedule during the reporting period. Actual results could differ from those estimates. For the year ended June 30, 2023, there were no expenditures passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The Authority has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX for Uniform Guidance awards. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. The Uniform Guidance provides for a 10% de minimis indirect cost rate election; however, the Authority did not make this election and uses a negotiated indirect cost rate in the accompanying Schedule.
Title: 3. COVID‑19 – Provider Relief Fund Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes all federal grants to Virginia Commonwealth University Health System Authority (the Authority) that had federal expenditure activity for the year ended June 30, 2023. The accompanying Schedule is presented using the accrual basis of accounting and in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with the applicable requirements, certain programs may be presented in a fiscal period based on program-specific guidance (Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements of the Authority. 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 amounts reported in the Schedule during the reporting period. Actual results could differ from those estimates. For the year ended June 30, 2023, there were no expenditures passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The Authority has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. In accordance with the U.S. Department of Health and Human Services’ requirements specific to Federal Assistance Listing 93.498, COVID 19 – Provider Relief Fund and American Rescue Plan (ARP) Distribution, the amount presented on the accompanying Schedule for the year ended June 30, 2023 for Federal Assistance Listing No. 93.498 relates to (i) Provider Relief Fund (PRF) payments received from July 1, 2021 through June 30, 2022 and (ii) used for PRF-eligible activity from the period January 1, 2020 through June 30, 2023. This payment receipt period and activity period and the resulting amount presented on the accompanying Schedule for the year ended June 30, 2023, reconciles to the PRF information reported to the Health Resources and Services Administration (HRSA) for PRF Reporting Periods 4 and 5 as follows: [See notes in table] Health and Human Services (HHS) has indicated the PRF Funds should be reported according to the reporting requirements of the HRSA PRF Reporting Portal (the “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 Portal after each Period’s deadline to use the funds (i.e., after the end of the Period of Availability). The accompanying Schedule includes $15,517,535 of PRF Funds received from HHS between July 1, 2021 through June 30, 2022. The PRF-eligible expenses attributable to Coronavirus Disease 2019 (COVID 19) and lost revenues incurred by the Authority during the period of availability for PRF Reporting Periods 4 and 5 (January 1, 2020 through June 30, 2023) are in excess of the general and targeted distributions received from July 1, 2021 through June 30, 2022 and, therefore, the amounts presented in the table above and on the accompanying Schedule are limited to the amount of such distributions. Additionally, any payment received related to entity lost revenues prior to acquisition or returned payments have not been included in the above schedule. The Authority also received PRF payments subsequent to June 30, 2023, which are required to be reported in subsequent HRSA PRF Reporting Periods and, accordingly, pursuant to the requirements specific to Federal Assistance Listing Number 93.498, activity related to such payments is excluded from the accompanying Schedule.
Title: 4. COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) (“FEMA”) Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes all federal grants to Virginia Commonwealth University Health System Authority (the Authority) that had federal expenditure activity for the year ended June 30, 2023. The accompanying Schedule is presented using the accrual basis of accounting and in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with the applicable requirements, certain programs may be presented in a fiscal period based on program-specific guidance (Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements of the Authority. 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 amounts reported in the Schedule during the reporting period. Actual results could differ from those estimates. For the year ended June 30, 2023, there were no expenditures passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The Authority has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures related to Assistance Listing 97.036 – COVID -19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) (“FEMA”) on the Schedule is the amount obligated within the year ended June 30, 2023. In response to the COVID-19 pandemic, the System purchased specialized medical equipment in order to treat COVID-19 patients and were claimed as reimbursement under the FEMA Public Assistance Grant Program. The COVID-19 Public Health Emergency officially ended May 11, 2023 in which, there were no adjustments necessary to the 2023 claims, however, there may be further adjustments to existing or future applications to account for other reductions as the Virginia Department of Emergency Management completes authorization and appropriately of the funds.
Title: 5. Noncash Federal Assistance Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes all federal grants to Virginia Commonwealth University Health System Authority (the Authority) that had federal expenditure activity for the year ended June 30, 2023. The accompanying Schedule is presented using the accrual basis of accounting and in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In accordance with the applicable requirements, certain programs may be presented in a fiscal period based on program-specific guidance (Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements of the Authority. 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 amounts reported in the Schedule during the reporting period. Actual results could differ from those estimates. For the year ended June 30, 2023, there were no expenditures passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The Authority has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Authority did not receive any noncash Federal assistance including donated personal protective equipment for the year ended June 30, 2023.

Finding Details

Criteria: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Condition: The Authority had not finalized the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2023 in a timely manner. Cause: The Schedule for the year ended June 30, 2023 included a number of COVID-19 programs. Various individuals in the Authority were involved and responsible for monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. COVID-19 also impacted a number of resources within the Authority causing various constraints. Management continued to enhance procedures related to preparation and assessment of the Schedule. Effect or potential effect: The reporting and verification of the completeness and accuracy of the expenditures required more time than expected due to the COVID-19 nature of the funds. Questioned Costs: None. Identification of a repeat finding: This is a repeat finding of Finding 2022-001 in the prior year. Context: The audit was not completed and the reporting submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period as required by the Uniform Guidance. Recommendation: The Authority’s policy and procedures should be designed to ensure timely reporting as required by the Uniform Guidance. View of responsible officials: There is no disagreement with the audit finding.
Criteria: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” The terms and conditions of the award require the recipient to submit reports to the secretary of Health and Human Services (HHS) for each reporting period to ensure compliance with conditions that are imposed on the payment, and such report shall be in such form, with such content, as specified by the secretary of HHS in program instructions directed to all recipients. Condition: Management did not have sufficiently designed internal controls to review the supporting documentation used in the lost revenue calculation and the data submitted in the HHS portal. The amount of the revenue reported to Health Resources and Services Administration (HRSA) in the HHS portal for Periods 1 through 5 did not agree to the amounts recorded in the general ledger, resulting in the Period 4 and 5 reports to have incorrect cumulative revenues for July 1, 2022 to June 30, 2023. Cause: The Authority did not retain sufficient appropriate evidence of review and approval of amounts quantified as lost revenues attributable to COVID-19 that have not been reimbursed from other sources or that other sources are not obligated to reimburse. Management entered the incorrect information into the HHS portal. Management’s internal controls over the review and approval of the HHS portal data was not sufficiently robust to identify data input errors. Effect or potential effect: A lack of internal controls over the review of the lost revenue calculation submitted in the HHS portal could results in a misstatement of the amounts reported in the HHS portal. Potential effects include inappropriate amounts of lost revenue quantified that could impact the complete and accurate reporting of such amounts submitted to HRSA’s PRF Reporting Portal and amounts ultimately received by the Authority that could result in funds ultimately being required to be returned to HRSA. Questioned costs: None. Identification of a repeat finding: This is a repeat finding of Finding 2022-002 in the prior year. Context: There was a total of 4 HHS portal submission for the year ended June 30, 2023. The lost revenue reported on the Authority’s submission to HRSA’s PRF Reporting Portal amounted to $313,560,072. The total lost revenue supported by the Authority’s underlying calculations of lost revenue amounted to $263,152,407 for the year ended June 30, 2023. Therefore, Management reported $50,407,665 more in lost revenues in the portal than their supporting calculation. This difference had no impact on the amount received by the Authority from HHS under this Program. Recommendation: We recommend that Management develop and implement effective internal controls to ensure lost revenue calculations are reviewed and approved to ensure that the report submissions are accurate. The Authority should retain sufficient supporting documentation to support the lost revenue calculation was reviewed, approved, and calculated in accordance with the terms of the federal program during the period. View of responsible officials: There is no disagreement with the audit finding.
Criteria: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Condition: The Authority had not finalized the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2023 in a timely manner. Cause: The Schedule for the year ended June 30, 2023 included a number of COVID-19 programs. Various individuals in the Authority were involved and responsible for monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. COVID-19 also impacted a number of resources within the Authority causing various constraints. Management continued to enhance procedures related to preparation and assessment of the Schedule. Effect or potential effect: The reporting and verification of the completeness and accuracy of the expenditures required more time than expected due to the COVID-19 nature of the funds. Questioned Costs: None. Identification of a repeat finding: This is a repeat finding of Finding 2022-001 in the prior year. Context: The audit was not completed and the reporting submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period as required by the Uniform Guidance. Recommendation: The Authority’s policy and procedures should be designed to ensure timely reporting as required by the Uniform Guidance. View of responsible officials: There is no disagreement with the audit finding.
Criteria: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Condition: The Authority had not finalized the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2023 in a timely manner. Cause: The Schedule for the year ended June 30, 2023 included a number of COVID-19 programs. Various individuals in the Authority were involved and responsible for monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. COVID-19 also impacted a number of resources within the Authority causing various constraints. Management continued to enhance procedures related to preparation and assessment of the Schedule. Effect or potential effect: The reporting and verification of the completeness and accuracy of the expenditures required more time than expected due to the COVID-19 nature of the funds. Questioned Costs: None. Identification of a repeat finding: This is a repeat finding of Finding 2022-001 in the prior year. Context: The audit was not completed and the reporting submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period as required by the Uniform Guidance. Recommendation: The Authority’s policy and procedures should be designed to ensure timely reporting as required by the Uniform Guidance. View of responsible officials: There is no disagreement with the audit finding.
Criteria: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” The terms and conditions of the award require the recipient to submit reports to the secretary of Health and Human Services (HHS) for each reporting period to ensure compliance with conditions that are imposed on the payment, and such report shall be in such form, with such content, as specified by the secretary of HHS in program instructions directed to all recipients. Condition: Management did not have sufficiently designed internal controls to review the supporting documentation used in the lost revenue calculation and the data submitted in the HHS portal. The amount of the revenue reported to Health Resources and Services Administration (HRSA) in the HHS portal for Periods 1 through 5 did not agree to the amounts recorded in the general ledger, resulting in the Period 4 and 5 reports to have incorrect cumulative revenues for July 1, 2022 to June 30, 2023. Cause: The Authority did not retain sufficient appropriate evidence of review and approval of amounts quantified as lost revenues attributable to COVID-19 that have not been reimbursed from other sources or that other sources are not obligated to reimburse. Management entered the incorrect information into the HHS portal. Management’s internal controls over the review and approval of the HHS portal data was not sufficiently robust to identify data input errors. Effect or potential effect: A lack of internal controls over the review of the lost revenue calculation submitted in the HHS portal could results in a misstatement of the amounts reported in the HHS portal. Potential effects include inappropriate amounts of lost revenue quantified that could impact the complete and accurate reporting of such amounts submitted to HRSA’s PRF Reporting Portal and amounts ultimately received by the Authority that could result in funds ultimately being required to be returned to HRSA. Questioned costs: None. Identification of a repeat finding: This is a repeat finding of Finding 2022-002 in the prior year. Context: There was a total of 4 HHS portal submission for the year ended June 30, 2023. The lost revenue reported on the Authority’s submission to HRSA’s PRF Reporting Portal amounted to $313,560,072. The total lost revenue supported by the Authority’s underlying calculations of lost revenue amounted to $263,152,407 for the year ended June 30, 2023. Therefore, Management reported $50,407,665 more in lost revenues in the portal than their supporting calculation. This difference had no impact on the amount received by the Authority from HHS under this Program. Recommendation: We recommend that Management develop and implement effective internal controls to ensure lost revenue calculations are reviewed and approved to ensure that the report submissions are accurate. The Authority should retain sufficient supporting documentation to support the lost revenue calculation was reviewed, approved, and calculated in accordance with the terms of the federal program during the period. View of responsible officials: There is no disagreement with the audit finding.
Criteria: In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Condition: The Authority had not finalized the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended June 30, 2023 in a timely manner. Cause: The Schedule for the year ended June 30, 2023 included a number of COVID-19 programs. Various individuals in the Authority were involved and responsible for monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. COVID-19 also impacted a number of resources within the Authority causing various constraints. Management continued to enhance procedures related to preparation and assessment of the Schedule. Effect or potential effect: The reporting and verification of the completeness and accuracy of the expenditures required more time than expected due to the COVID-19 nature of the funds. Questioned Costs: None. Identification of a repeat finding: This is a repeat finding of Finding 2022-001 in the prior year. Context: The audit was not completed and the reporting submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period as required by the Uniform Guidance. Recommendation: The Authority’s policy and procedures should be designed to ensure timely reporting as required by the Uniform Guidance. View of responsible officials: There is no disagreement with the audit finding.