Audit 390602

Finding: Reporting and Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Assistance Listing No. 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) U.S. Department of Health and Human Services Criteria or Specific Requirement – Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). 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 2019 (COVID-19). Entities that receive more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. In addition, the Organization is required to implement and maintain internal controls over financial reporting. Condition – The Organization submitted incorrect figures reported for Expenses in the Period 1 Health Resources & Services Administrator report (HRSA). Questioned Costs – $1,107,540 was the total amount of expenses determined to be over-reported in period 1 reporting portal. Context – The errors were the result of a keying error where the amounts in Supplies and Other Healthcare Expenses were duplicated. There were also general and administrative expenses submitted based upon an allocated percentage of total expenses incurred that was unable to be fully substantiated Effect – The Organization submitted expenses under the PRF program that were incorrect. Cause – There was no formal approval of final report prior to submission to HRSA. Identification as a Repeat Finding – Not a repeat finding Recommendation – The Organization should continue to improve its formal review of HRSA report prior to submission. View of Responsible Official and Planned Corrective Actions – The Organization agrees with the finding. See separate report for planned corrective actions

Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Assistance Listing No. 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) U.S. Department of Health and Human Services Criteria or Specific Requirement – Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). 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 2019 (COVID-19). Entities that receive more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. In addition, the Organization is required to implement and maintain internal controls over financial reporting. Condition – The Organization reported COVID-19-related expenditures that were outside the Period of Availability according to the Health and Human Services (HHS) FAQ for Provider Relief Fund (PRF) Questioned Costs – $179,935 was the total amount of expenses determined to be over-reported to the federal program. Context – Upon testing the compliance requirements of this program, it was determined that the expenditure items were outside the period of availabilty as is consistent with existing guidance provided by HHS. Effect – The Organization submitted expenses under the PRF program that are outside of the period of availibility. Cause – The guidance provided by HHS to providers across the country as to how to report their COVID-19-related expenses and lost revenues is, at times, difficult to comprehend and apply. The Organization incorrectly applied guidance. Identification as a Repeat Finding – Not a repeat finding Recommendation – The Organization should continue to improve its understanding of the guidance related to this type of reporting and work with their external advisors to identify areas for improvement prior to submission to the Provider Relief Fund Reporting portal. View of Responsible Official and Planned Corrective Actions – The Organization agrees with the finding. See separate report for planned corrective actions

Finding: Reporting and Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Assistance Listing No. 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) U.S. Department of Health and Human Services Criteria or Specific Requirement – Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). 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 2019 (COVID-19). Entities that receive more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. In addition, the Organization is required to implement and maintain internal controls over financial reporting. Condition – The Organization reported Patient Revenue on the HRSA submission that did not agree to the Patient Revenue per the audited financial statements. Questioned Costs – Unknown Context – Revenue utilized in the lost revenue calculation for Period 1 was not reconciled to patient revenue on the audited financial statements. The Organization reperformed the lost revenue calculation and provided this calculation after the submission of the Period 1 HRSA report. Effect – The Organization submitted incorrect lost revenue figures in the Period 1 HRSA submission. Cause – The Organization Regional Controller failed to review the lost revenue calculation prior to submission. Identification as a Repeat Finding – Not a repeat finding Recommendation – The Organziation should continue to improve its formal review of HRSA report and Lost Revenue Calculation prior to submission. View of Responsible Official and Planned Corrective Actions – The Organization agrees with the finding. See separate report for planned corrective actions