2022-002 U.S. Department of Health and Human Services Federal Assistance Listing Number 93.498 COVID-19 Provider Relief Fund - Award Year 2020 Criteria or Specific Requirement ? Reporting (45 CFR 75.342). The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, P.L. 116-136) to reimburse, through grants or other mechanisms, eligible health care providers for increased expenses or lost revenue attributable to Coronavirus Disease (COVID-19). Entities that received more than $10,000 (either one time or in the aggregate) are required to report the use of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. Condition ? The University is required to prepare and submit period two Provider Relief Fund reporting to HHS. This report is to be prepared using accurate financial information; however, the University incorrectly reported two quarters of 2020 patient revenues out of a total of twelve quarters reported covering calendar years 2019, 2020 and 2021. Questioned Costs ? None Context ? Upon testing the period two Provider Relief Fund report and total lost revenue calculation, it was determined that the lost revenues were being reported incorrectly and not consistent with current guidance provided by HHS. The University used clinic revenue reports that did not agree with the accrual basis of revenue recognition for the second and third quarters of 2020. This did not result in any misstatement of the total value reported of lost revenue for the calendar year ended December 31, 2020; however, did incorrectly report which quarters the lost revenue related to. Effect ? Lost revenue reported for calendar year 2020 was accurate; however, a timing difference resulted in inaccurate quarterly reporting for two consecutive quarters. Cause ? The guidance provided by HHS to providers across the country as to how to report their lost revenues is, at times, difficult to comprehend and apply. When accumulating revenue reports, the University utilized individual clinic reports which had not been properly adjusted for two quarters to recognize the revenue on the accrual basis of accounting. The University made a good faith effort to accurately report lost revenues using guidance available at the time of reporting. Additional guidance was made available subsequent to report filing deadlines. Identification as a Repeat Finding ? Not applicable. Recommendation ? The University should continue to improve its understanding of the guidance related to this type of reporting. Policies and procedures over federal grant reports should be modified to ensure reports are prepared using appropriate information. Views of Responsible Officials and Planned Corrective Actions ? The University is going to continue to improve its understanding of the guidance related to this type of reporting and work with their external advisors to ensure future portal submissions, if any, are compliant with said guidance.
2022-001 U.S. Department of Health and Human Services Federal Assistance Listing Number 93.107 Area Health Education Centers - Award Year 2022, Award Number - 5 U77HP03042-24-00 Criteria or Specific Requirement ? Period of Performance - A non-federal entity may charge to the federal award only allowable costs incurred during the period of performance (45 CFR 75.309). Condition ? One expenditure was incurred outside of the applicable period of performance for the grant. Questioned Costs ? $2,500 of expenses charged to the Area Health Education Center (ALN 93.107), grant award number 5 U77HP03042-24-00. Context ? Out of a population of 118 expenditures totaling $939,314, 12 expenditures totaling $34,059 were tested to verify if the transaction charged to the grant was incurred within the period of performance. One expense for $2,500 charged to the award near the end of the period of performance (9/1/2020-8/31/2021) was related to and incurred outside the period (related to services provided for the period 10/1/2021-9/30/2022). The sample was not, and was not intended to be, a statistically valid sample. Effect ? One expenditure was outside the period of performance. Cause ? Oversight by management. The grant renews on an ongoing basis and the expense was charged to the incorrect grant period. Identification as a Repeat Finding ? Not applicable. Recommendation ? The University should implement monitoring policies and procedures to ensure that expenditures fall within the appropriate budget period. Views of Responsible Officials and Planned Corrective Actions ? Recognizing this expense was monitored through the internal control framework and still resulted in a human error, the proposed corrective action plan will focus on two areas: correcting the cost to the appropriate budget period, and coaching the members of the control system regarding the period of performance, specific to contractual services, membership services, and subscription services that are delivered over time to heighten awareness.
2022-002 U.S. Department of Health and Human Services Federal Assistance Listing Number 93.498 COVID-19 Provider Relief Fund - Award Year 2020 Criteria or Specific Requirement ? Reporting (45 CFR 75.342). The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, P.L. 116-136) to reimburse, through grants or other mechanisms, eligible health care providers for increased expenses or lost revenue attributable to Coronavirus Disease (COVID-19). Entities that received more than $10,000 (either one time or in the aggregate) are required to report the use of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. Condition ? The University is required to prepare and submit period two Provider Relief Fund reporting to HHS. This report is to be prepared using accurate financial information; however, the University incorrectly reported two quarters of 2020 patient revenues out of a total of twelve quarters reported covering calendar years 2019, 2020 and 2021. Questioned Costs ? None Context ? Upon testing the period two Provider Relief Fund report and total lost revenue calculation, it was determined that the lost revenues were being reported incorrectly and not consistent with current guidance provided by HHS. The University used clinic revenue reports that did not agree with the accrual basis of revenue recognition for the second and third quarters of 2020. This did not result in any misstatement of the total value reported of lost revenue for the calendar year ended December 31, 2020; however, did incorrectly report which quarters the lost revenue related to. Effect ? Lost revenue reported for calendar year 2020 was accurate; however, a timing difference resulted in inaccurate quarterly reporting for two consecutive quarters. Cause ? The guidance provided by HHS to providers across the country as to how to report their lost revenues is, at times, difficult to comprehend and apply. When accumulating revenue reports, the University utilized individual clinic reports which had not been properly adjusted for two quarters to recognize the revenue on the accrual basis of accounting. The University made a good faith effort to accurately report lost revenues using guidance available at the time of reporting. Additional guidance was made available subsequent to report filing deadlines. Identification as a Repeat Finding ? Not applicable. Recommendation ? The University should continue to improve its understanding of the guidance related to this type of reporting. Policies and procedures over federal grant reports should be modified to ensure reports are prepared using appropriate information. Views of Responsible Officials and Planned Corrective Actions ? The University is going to continue to improve its understanding of the guidance related to this type of reporting and work with their external advisors to ensure future portal submissions, if any, are compliant with said guidance.
2022-001 U.S. Department of Health and Human Services Federal Assistance Listing Number 93.107 Area Health Education Centers - Award Year 2022, Award Number - 5 U77HP03042-24-00 Criteria or Specific Requirement ? Period of Performance - A non-federal entity may charge to the federal award only allowable costs incurred during the period of performance (45 CFR 75.309). Condition ? One expenditure was incurred outside of the applicable period of performance for the grant. Questioned Costs ? $2,500 of expenses charged to the Area Health Education Center (ALN 93.107), grant award number 5 U77HP03042-24-00. Context ? Out of a population of 118 expenditures totaling $939,314, 12 expenditures totaling $34,059 were tested to verify if the transaction charged to the grant was incurred within the period of performance. One expense for $2,500 charged to the award near the end of the period of performance (9/1/2020-8/31/2021) was related to and incurred outside the period (related to services provided for the period 10/1/2021-9/30/2022). The sample was not, and was not intended to be, a statistically valid sample. Effect ? One expenditure was outside the period of performance. Cause ? Oversight by management. The grant renews on an ongoing basis and the expense was charged to the incorrect grant period. Identification as a Repeat Finding ? Not applicable. Recommendation ? The University should implement monitoring policies and procedures to ensure that expenditures fall within the appropriate budget period. Views of Responsible Officials and Planned Corrective Actions ? Recognizing this expense was monitored through the internal control framework and still resulted in a human error, the proposed corrective action plan will focus on two areas: correcting the cost to the appropriate budget period, and coaching the members of the control system regarding the period of performance, specific to contractual services, membership services, and subscription services that are delivered over time to heighten awareness.