Audit 352093

FY End
2024-06-30
Total Expended
$127.31M
Findings
2
Programs
19
Year: 2024 Accepted: 2025-03-31

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
551394 2024-001 - - AB
1127836 2024-001 - - AB

Contacts

Name Title Type
RFKAVNHKKVB3 Dean Silfies Auditee
4845263784 Victoria Brennan Auditor
No contacts on file

Notes to SEFA

Title: 1. Organization Accounting Policies: 2. Significant Accounting Policies The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. De Minimis Rate Used: N Rate Explanation: The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award. St. Luke’s Health Network, Inc. and Controlled Entities (the “Network”) is inclusive of St. Luke’s Health Network, Inc. (“Parent”) and controlled entities as described within Footnote 1 of the footnotes to the Consolidated Financial Statements. The Network is a not-for-profit tax-exempt corporation which controls eight acute care hospitals, an organization of physician practices and several other healthcare related organizations serving Bethlehem, Pennsylvania and surrounding communities. The St. Luke’s Hospital School of Nursing of Bethlehem, Pennsylvania (“School”) at St. Luke’s Hospital of Bethlehem, Pennsylvania (“Hospital”) is a controlled entity of the Parent. The School provides a program of classroom and clinical preparation for the nursing profession. The Student Financial Assistance expenditures are solely for the benefit of the School. The Research and Development expenditures are for the benefit of the acute care hospitals and the Other Sponsored Program expenditures benefit the acute care hospitals and other entities across the Network. The Network's consolidated financial statements include the operations of Penn Foundation, Inc., Penn Villa Corp, and Penn Gardens, Inc., which are not included in the Network’s schedule of expenditures of federal awards during the year ended June 30, 2024. This is due to the fact that these entities engaged other auditors to perform an audit in accordance with the Uniform Guidance.
Title: 2. Significant Accounting Policies Accounting Policies: 2. Significant Accounting Policies The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. De Minimis Rate Used: N Rate Explanation: The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award. The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award.
Title: 3. Subrecipients Accounting Policies: 2. Significant Accounting Policies The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. De Minimis Rate Used: N Rate Explanation: The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award. The Network did not pass through any funds to subrecipients for the year ended June 30, 2024 and thus this information is not applicable to the Schedule.
Title: 4. Department of Health and Human Services Provider Relief Funds Accounting Policies: 2. Significant Accounting Policies The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. De Minimis Rate Used: N Rate Explanation: The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award. The Schedule includes grant activity related to the Department of Health and Human Services ("HHS") Provider Relief Fund Assistance Listing Number 93.498. As required based on guidance in the 2024 OMB Compliance Supplement, the Schedule includes all Period 6 and 7 funds received between July 1, 2022 and June 30, 2023 and expended by June 30, 2024 as reported to HRSA via the PRF Reporting Portal, except for the entities noted as being excluded from this report in Note 1. The Schedule thus includes $182,497 in lost revenue. Given the timing covered by Period 6 and 7 funds, certain of these expenses were reflected in the Network’s fiscal year 2023 financial statements. Additionally, lost revenue does not represent an expenditure in the Network’s financial statements and thus is a reconciling item between the federal expenses in the Network’s financial statements and the amount included on the Schedule.
Title: 5. Loan Programs Accounting Policies: 2. Significant Accounting Policies The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. De Minimis Rate Used: N Rate Explanation: The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award. As of June 30, 2024, the Network had $90,793,915 in debt payable to the United States Department of Agriculture (Assistance Listing #10.766). Details of the debt balances outstanding, maturity dates, and other related information is included in Note 12 to the consolidated financial statements.
Title: 6. Federal Emergency Management Agency (FEMA) Public Assistance Accounting Policies: 2. Significant Accounting Policies The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) summarizes the expenditures of the Network under programs of the federal government for the year ended June 30, 2024. The information presented in the Schedule is presented on the accrual basis of accounting, which is in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only the federal award activity of the Network, it is not intended to and does not present the financial position, changes in net assets, and cash flows of the Network. For purposes of the Schedule, federal awards include all grants, contracts, and similar agreements entered into directly between the Network and agencies and departments of the federal government and all sub-awards to the Network by nonfederal organizations pursuant to federal grants, contracts, and similar agreements. De Minimis Rate Used: N Rate Explanation: The Network does not use the 10% de minimis indirect cost rate for sponsored programs, as described in Section 200.414 of the Uniform Guidance. The Network charges indirect costs to federal awards based on award-specific rates as defined in each grant award. The Network applied for reimbursement of certain expenses related to the COVID-19 pandemic under Assistance Listing #97.036, FEMA Public Assistance through the commonwealth of Pennsylvania. Expenditures are reflected in the Schedule in the year in which a project application is obligated and expenses have been incurred. The Schedule thus includes $26,561,556 of expenditures incurred in fiscal years 2021 and 2022, which were obligated in fiscal year 2024 and represents a reconciling item between the federal expenses in the Network’s financial statements and the amount included on the Schedule.

Finding Details

2024-001 – Duplicate Invoices Submitted for Reimbursement Cluster: Community Facilities Loan and Grant Cluster Federal Granting Agency: Department of Agriculture Award Name: Rural Housing Service Assistance Listing #: 10.766 Assistance Listing Title: Community Facility Loans and Grants Award Year: July 1, 2023 – June 30, 2024 Criteria The 2 CFR Part 200 defines an improper payment as a payment that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. This definition includes duplicate payments as an example. Condition Through PwC's testing of the reimbursement of the expenditures relating to the Facilities Loan, it was noted that three invoices submitted for reimbursement were duplicates for which the Company had already been reimbursed. These duplicated invoices totaled $106,000. Cause As part of management process for providing invoices for reimbursement, it was noted that there was not a process to review the prior invoice submission to make sure that invoices had not been previously submitted for reimbursement. Effect The submission for reimbursement relating to the Facilities Loans were overdrawn by $106,000. Questioned Costs $106,000 Recommendation PwC recommended the Company refund the overdrawn amount of $106,000. Management should also implement a control to review the prior reimbursement submissions to verify that there are no duplicate invoices submitted in the current period. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.
2024-001 – Duplicate Invoices Submitted for Reimbursement Cluster: Community Facilities Loan and Grant Cluster Federal Granting Agency: Department of Agriculture Award Name: Rural Housing Service Assistance Listing #: 10.766 Assistance Listing Title: Community Facility Loans and Grants Award Year: July 1, 2023 – June 30, 2024 Criteria The 2 CFR Part 200 defines an improper payment as a payment that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. This definition includes duplicate payments as an example. Condition Through PwC's testing of the reimbursement of the expenditures relating to the Facilities Loan, it was noted that three invoices submitted for reimbursement were duplicates for which the Company had already been reimbursed. These duplicated invoices totaled $106,000. Cause As part of management process for providing invoices for reimbursement, it was noted that there was not a process to review the prior invoice submission to make sure that invoices had not been previously submitted for reimbursement. Effect The submission for reimbursement relating to the Facilities Loans were overdrawn by $106,000. Questioned Costs $106,000 Recommendation PwC recommended the Company refund the overdrawn amount of $106,000. Management should also implement a control to review the prior reimbursement submissions to verify that there are no duplicate invoices submitted in the current period. Management’s Views and Corrective Action Plan Management's views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.