Audit 37070

FY End
2022-06-30
Total Expended
$9.72M
Findings
2
Programs
7
Year: 2022 Accepted: 2023-03-30

Organization Exclusion Status:

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Contacts

Name Title Type
Q8FZPLN67P88 Kendra Miller Auditee
3522657621 John Di Santo Auditor
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Notes to SEFA

Accounting Policies: 1.Basis of PresentationThe accompanying Schedule of Expenditures of Federal Awards (the Schedule) include the federal grant activity of Shands Teaching Hospital and Clinics, Inc. and Subsidiaries (Shands), and is presented on the accrual basis of accounting. The information in the Schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedules present only a selected portion of the operations of Shands, they are not intended to and do not present the financial position, changes in net position, or cash flows of Shands. The purpose of the Schedule is to present a summary of those activities of Shands for the year ended June 30, 2020, which have been financed by the federal government. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants and contracts. Direct and indirect costs are charged to awards in accordance with cost principles contained in the Department of Health and Human Services, Office of the Assistant Secretary Comptroller (OASC), OASC-3 Hospital Cost Principles (or CFR Part 45, Part 74, Appendix E) and Uniform Guidance, 2 CFR Part 200, Subpart E Cost Principles. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. 2. COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (Assistance Listing No. 93.498) The Schedule of Expenditures of Federal Awards (Schedule) includes $4,552,823 received from the U.S. Department of Health and Human Services (HHS) between July 1, 2020 and June 30, 2021 under the Provider Relief Fund (PRF) program of Assistance Listing No. 93.498. In accordance with guidance from HHS, these amounts are presented as Periods 2 and Period 3 in the HHS PRF Reporting Portal. This amount was recognized as federal and state grant appropriations in Shands consolidated basic financial statements in the consolidated statement of revenues, expenses and changes in net position for the year ended June 30, 2021. Due to the PRF Reporting Portal requirements, this amount is not the total PRF received and/or recognized by Shands as revenue in Shands consolidated basic financial statements for the year ended June 30, 2022. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

Section III?Federal Award Findings and Questioned Costs Finding No. 2022-001 ? Activities Allowed or Unallowed; Allowable Costs and Eligibility ? Significant Deficiency in Internal Control Over Compliance Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Pass-Through Award Numbers: Not applicable Pass-Through Award Period of Performance: 07/01/2021?6/30/2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Specific program terms and conditions established by HHS state that the program provides claims reimbursements to eligible health care providers for conducting COVID-19 testing for the uninsured, treating uninsured individuals with a COVID-19 diagnosis, and administering FDA-authorized or FDA-licensed COVID-19 vaccines to uninsured individuals. Condition: Management developed a robust process to ensure that amounts submitted to and reimbursed by the COVID-19 Testing for the Uninsured program were in accordance with federal program requirements. During our testing of such controls in place for this program, we were able to corroborate through inquiry of management and reperformance that the controls were in operation, however support that would allow us to inspect evidence as to the consistent operating effectiveness and precision included in the controls was not consistently retained. Cause: In certain instances, support that would allow us to inspect evidence as to the consistent operating effectiveness and precision included in the controls was not retained. Questioned Costs: None. Context: Total federal expenditures for Assistance Listing 93.461 totaled $4,745,701 for the year ended June 30, 2022. We selected 60 transactions totaling $2,291,538 for testing. We did not identify any instances of noncompliance in our sample. Effect or Potential Effect: Potential effects include providing services to ineligible patients, services reimbursed by HRSA were not allowable or patients were inappropriately billed for services that HRSA reimbursed under this program. This could ultimately result in funds being received for ineligible patients and/or for unallowable services provided to patients. Identification as a Repeat Finding, If Applicable: The finding is a repeat finding of Finding 2021-003 in the prior year. Recommendation: Management should retain documentation of the precision at which the controls were carried out as designed sufficient to test internal control over compliance. Views of Responsible Officials: Management concurs with this finding. See separate management?s Corrective Action Plan.
Section III?Federal Award Findings and Questioned Costs Finding No. 2022-001 ? Activities Allowed or Unallowed; Allowable Costs and Eligibility ? Significant Deficiency in Internal Control Over Compliance Identification of the Federal Program: Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Pass-Through Award Numbers: Not applicable Pass-Through Award Period of Performance: 07/01/2021?6/30/2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Specific program terms and conditions established by HHS state that the program provides claims reimbursements to eligible health care providers for conducting COVID-19 testing for the uninsured, treating uninsured individuals with a COVID-19 diagnosis, and administering FDA-authorized or FDA-licensed COVID-19 vaccines to uninsured individuals. Condition: Management developed a robust process to ensure that amounts submitted to and reimbursed by the COVID-19 Testing for the Uninsured program were in accordance with federal program requirements. During our testing of such controls in place for this program, we were able to corroborate through inquiry of management and reperformance that the controls were in operation, however support that would allow us to inspect evidence as to the consistent operating effectiveness and precision included in the controls was not consistently retained. Cause: In certain instances, support that would allow us to inspect evidence as to the consistent operating effectiveness and precision included in the controls was not retained. Questioned Costs: None. Context: Total federal expenditures for Assistance Listing 93.461 totaled $4,745,701 for the year ended June 30, 2022. We selected 60 transactions totaling $2,291,538 for testing. We did not identify any instances of noncompliance in our sample. Effect or Potential Effect: Potential effects include providing services to ineligible patients, services reimbursed by HRSA were not allowable or patients were inappropriately billed for services that HRSA reimbursed under this program. This could ultimately result in funds being received for ineligible patients and/or for unallowable services provided to patients. Identification as a Repeat Finding, If Applicable: The finding is a repeat finding of Finding 2021-003 in the prior year. Recommendation: Management should retain documentation of the precision at which the controls were carried out as designed sufficient to test internal control over compliance. Views of Responsible Officials: Management concurs with this finding. See separate management?s Corrective Action Plan.