Audit 36845

FY End
2022-12-31
Total Expended
$180.50M
Findings
6
Programs
29
Organization: Ochsner Clinic Foundation (LA)
Year: 2022 Accepted: 2023-06-27

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
39424 2022-001 - - ABH
39425 2022-001 - - ABH
39426 2022-001 - - ABH
615866 2022-001 - - ABH
615867 2022-001 - - ABH
615868 2022-001 - - ABH

Programs

ALN Program Spent Major Findings
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $82.07M Yes 1
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $65.36M Yes 1
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $19.02M Yes 0
32.006 Covid-19 - Covid-19 Telehealth Program $1.18M - 0
93.732 Mental and Behavioral Health Education and Training Grants $926,604 - 0
93.461 Covid-19 - Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $845,641 - 0
93.697 Covid-19 - Covid-19 Testing and Mitigation for Rural Health Clinics $755,709 - 0
93.969 Pphf Geriatric Education Centers $444,671 - 0
93.279 Drug Abuse and Addiction Research Programs $206,202 - 0
93.399 Cancer Control $174,665 - 0
93.838 Lung Diseases Research $135,021 - 0
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $81,000 - 0
93.865 Child Health and Human Development Extramural Research $64,942 - 0
93.945 Assistance Programs for Chronic Disease Prevention and Control $57,270 - 0
93.866 Aging Research $52,492 - 0
93.361 Nursing Research $46,536 - 0
93.307 Minority Health and Health Disparities Research $26,509 - 0
93.837 Cardiovascular Diseases Research $26,072 - 0
93.350 National Center for Advancing Translational Sciences $20,000 - 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $19,302 - 0
93.859 Biomedical Research and Research Training $18,429 - 0
93.397 Cancer Centers Support Grants $17,615 - 0
12.420 Military Medical Research and Development $10,000 - 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $9,506 - 0
10.874 Delta Health Care Services Grant Program $7,815 - 0
93.213 Research and Training in Complementary and Integrative Health $4,908 - 0
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $1,395 - 0
93.310 Trans-Nih Research Support $1,210 - 0
93.855 Allergy and Infectious Diseases Research $852 - 0

Contacts

Name Title Type
GBPMHQM2SRL3 Giancarlo Campi Auditee
5042207009 Scott Enos Auditor
No contacts on file

Notes to SEFA

Title: Provider Relief Fund Accounting Policies: 1. Summary of Significant Accounting Policies: Basis of Accounting: The accompanying Schedule of Expenditures of Federal Awards (SEFA) includes the federal grant activity of Ochsner Clinic Foundation and Subsidiaries and is presented on the accrual basis of accounting. The information in the SEFA is presented 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). Therefore, some amounts presented in the SEFA may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of Ochsner Clinic Foundation and Subsidiaries. For purposes of the SEFA, federal awards include any assistance provided by a federal agency, directly, or indirectly, in the form of grants, contracts, cooperative agreements, loan and loan guarantees, or other non-cash assistance. The SEFA does not include payments received under the traditional Medicare and Medicaid reimbursement programs, as these programs are outside the scope of the Uniform Guidance. There were no donated goods and personal protective equipment received from federal sources that required recognition or disclosure in the notes to the SEFA. De Minimis Rate Used: N Rate Explanation: 2. Indirect Costs: Ochsner Clinic Foundation and Subsidiaries does not use the 10 percent de minimis indirect cost rate provided for in the Uniform Guidance. 3. Provider Relief Fund: The amount presented on the SEFA for Assistance Listing Number 93.498, COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF Funds), is for the year ended December 31, 2022. The amount presented reconciles to the Provider Relief Fund (PRF) information reported to the Health Resources and Services Administration (HRSA) as follows: See the Notes to the SEFA for table. Health and Human Services (HHS) has indicated the PRF Funds on the SEFA be reported corresponding to reporting requirements of the HRSA PRF Reporting 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 HRSA PRF Reporting Portal after each Periods deadline to use the funds (i.e., after the end of the Period of Availability). The SEFA includes $19,015,193 of PRF Funds received from HHS between January 1, 2021 through December 31, 2021. In accordance with guidance from HHS, these amounts are presented as Period 4. Such amount was recognized as other operating revenues in Ochsner Clinic Foundation and Subsidiaries' consolidated financial statements in the year ended December 31, 2021.
Title: Disaster Grants Public Assistance (Presidentially Declared Disasters) Accounting Policies: 1. Summary of Significant Accounting Policies: Basis of Accounting: The accompanying Schedule of Expenditures of Federal Awards (SEFA) includes the federal grant activity of Ochsner Clinic Foundation and Subsidiaries and is presented on the accrual basis of accounting. The information in the SEFA is presented 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). Therefore, some amounts presented in the SEFA may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of Ochsner Clinic Foundation and Subsidiaries. For purposes of the SEFA, federal awards include any assistance provided by a federal agency, directly, or indirectly, in the form of grants, contracts, cooperative agreements, loan and loan guarantees, or other non-cash assistance. The SEFA does not include payments received under the traditional Medicare and Medicaid reimbursement programs, as these programs are outside the scope of the Uniform Guidance. There were no donated goods and personal protective equipment received from federal sources that required recognition or disclosure in the notes to the SEFA. De Minimis Rate Used: N Rate Explanation: 2. Indirect Costs: Ochsner Clinic Foundation and Subsidiaries does not use the 10 percent de minimis indirect cost rate provided for in the Uniform Guidance. 4. Disaster Grants - Public Assistance (Presidentially Declared Disasters): In fiscal year 2022, Ochsner Clinic Foundation and Subsidiaries received approval from the State of Louisiana Governor's Office of Homeland Security and Emergency Preparedness for 10 project worksheets related to the reimbursement of eligible expenditures of $89,714,772 incurred in previous fiscal years. These previous years expenditures are included in the SEFA in the current year in accordance with guidance provided by the Department of Homeland Security.

Finding Details

Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.