Criteria or specific requirement: Per ?200.313, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number (FAIN)), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per the Organization's additions to Property and Equipment Policy, expenditures for tangible assets used actively in business operations with a cost exceeding $5,000 and with a useful life exceeding two years should be capitalized. Also per ?200.313, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: We noted the Organization is not in compliance with requirements related to the Equipment/Real Property Management of grants. Questioned costs: None. Context: During our testing, we noted the following exceptions: ? 1 out of 2 equipment samples totaling $13,306 was not capitalized and therefore not included in the either the departments fixed asset software or year end Property and Equipment financial balance. This asset was originally purchased in fiscal year 2021. As such, the auditor could not trace the equipment to a listing and properly identify the equipment through physical inspection. ? The organization did not complete the required 2 year physical inventory of equipment for 1 out of 1 federally purchased equipment. The equipment was originally purchased in June 2020. ? The Organization was not aware of the Equipment/Real Property Management CFR Requirements and lacks a process to ensure the Organization is in compliance with Equipment/Real Property Management CFR requirements. Cause: Management oversight; lack of effective internal controls addressing the purchase of equipment with Federal Funds. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-001 Recommendation: We recommend that the Organization create effective internal controls and procedures over the purchase of Federally Funded Equipment and Real Property and a tracking methodology to properly identify equipment purchased with federal funds that allows for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The Organization did have two purchases in FY21 that were expensed versus being capitalized. The Organization failed to follow the capital purchasing policy. The Organization has educated responsible parties of the capital purchasing policy to avoid future occurrences. The Organization has updated processes in fiscal year 2023 to ensure the purchasing policy is followed. The executive director of the program will conduct an annual physical inventory of federal purchased equipment.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition: We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. Questioned costs: Unknown. Context: During our testing, we noted the following exceptions: ? The Organization?s procurement policy did not meet the requirements defined by 2 CFR 200. ? The Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). ? For 7 out of 7 covered transactions, it was noted the Organization did not verify that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction. Cause: The Organization lacks a uniform Procurement, Suspension & Debarment policy that is in compliance with the Federal regulations and/or the terms and conditions of the Federal award. Effect: The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Repeat Finding: Yes ? 2021-002. Recommendation: ? We recommend the Organization review and update its procurement policy to ensure the policy meets the 2 CFR Part 200 Procurement requirements. ? We recommend the Organization retain all documentation and support to show that the procurement policy was followed. ? We recommend the Organization review, update, and implement the current Suspension and Debarment Process as there is no currently defined process to complete the Suspension and Debarment checks prior to entering into a covered transaction. Views of responsible officials: The Organization was unaware of the need to have its policy include thresholds for purchases using federal funds. We will work with the responsible parties to develop a purchasing policy that meets the federal purchasing requirements. The Organization will adopt a procurement policy in fiscal year 2023. Also, vendors have been reviewed for suspension and debarment and a vendor log with the information was completed in fiscal year 2023.
Criteria or specific requirement: According to ?200.302 Financial management of 2 CFR Part 200, the non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must 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. Condition: We noted the Organization is not in compliance with requirements related to the reporting of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization did not complete the indirect costs section of the annual Federal Financial Report submitted during the fiscal year. Auditor noted a total of $74,062 was drawn in indirect costs for fiscal year 2022. ? The Organization is not reporting the action in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Cause: The Organization lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete, agree to supporting spreadsheets, submitted timely, and properly maintained in the files of the Organization. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-003 Recommendation: ? We recommend the Organization review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete and timely. ? Specific to special reports for FFATA, we recommend the Organization provide training on the requirements to those employees responsible for reporting the action in FSRS. Views of responsible officials: The Organization was unaware of the FFATA reporting requirement. The Organization will register and submit the FFATA. Also, the Organization failed to report the indirect costs on the FFR. The Organization has notified the responsible parties to avoid future occurrences. The FFR?s have been completed to report indirect costs separately in fiscal year 2023. The FFATA was submitted in fiscal year 2023 and will be updated yearly.
Criteria or specific requirement: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. ? Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Condition: We noted the Organization is not in compliance with requirements related to the subrecipient monitoring of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization lacked a process to review the audits of subrecipients that would allow the Organization to identify any potential deficiencies that would require follow-up. ? The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Cause: The Organization does not have internal controls in place to ensure compliance with Federal regulations or the terms and conditions of the Federal award. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients. Repeat Finding: Yes ? 2021-004 Recommendation: We recommend that the Organization create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have since followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors and one as a subrecipient which is described below: ? Union County General Hospital (UCGH): Both ROAMS and UCGH see this relationship as a contractor. The stipend pays for a Tele-OB room in their facility and the budget even lists rent as part of the reason for the stipend. The stipend per the MoU also supports their participation in the monthly Governing Council meetings, data collection, IT support for the program implementation and decision making. ? Questa Health Center/Presbyterian Medical Services (Questa): Both ROAMS and Questa see this relationship as a contractor. The stipend pays for an OB room in their facility and is even listed as rent in the stipend budget. The stipend per the MoU also supports their participation in the monthly Governing Council and decision making. ? UNM Envision (UNM): UNM declared a portion of their stipend over the three-year period they received as subrecipient. They declared $39,635 as subrecipient and they received a total of $68,000 from ROAMS. ROAMS always saw the relationship as a contractor and not a subrecipient and we do not understand why they have declared a portion of their stipend as subrecipient. UNM was not an essential grant partner, joined in year two to assist with data review, participated in the Governing Council, and ROAMS has a data evaluation agreement with UNM that we understood as a contract. This different understanding of the relationships highlights the audit finding that the type of relationship should be agreed upon upfront. ? Miners Colfax Medical Center (MCMC): sees themselves as a subrecipient and we agree. They are a state hospital and the other Labor and Delivery hospital in the ROAMS grant, and like Holy Cross Medical Center have a very high data reporting burden and serve as the home for the patients. The Memorandum of Agreement signed by all Network partners outlines their obligations in section IV Provision of Services and VI Records and Information (a. b. and c.). As we have investigated the monitoring of subrecipients verses a contractor, we have found that the same follow up is necessary, as long as the subrecipient receives less than $750,000 in federal funds in a year, which is the case for MCMC. Our procedures for paying the stipend for both the contractors and one subrecipient (MCMC), have been attendance at the monthly Governing Council meetings, and deliverables from data collection, to IT support and meetings, workflow meetings, and clinical meetings. Reminders of deliverables that are pending are in the monthly Governing Council notes as is the attendance. ROAMS and the network partners were very clear in written documents and practice that the quarterly stipend payment was linked to participation and deliverables. We can provide you with monthly Governing Council notes to show this. A draft policy is in the works that will have the network partners formally declare their relationship as contractor or subrecipient and outline the monitoring of subrecipients. From our research we do not see the subrecipient monitoring being significantly different from a contractor unless the $750,000 threshold is met. The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors. The ROAMS Director will request from the entities the audits for the CFO review to review for deficiencies on an annual basis.
Criteria or specific requirement: According to ?200.302 Financial management of 2 CFR Part 200, the non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must 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. Condition: We noted the Organization is not in compliance with requirements related to the reporting of grants. Questioned costs: $1,062,184 Context: During our testing, we noted the following exception: ? The Organization did not reduce the PRF expenses claimed by the amounts reimbursed by Medicare through the cost report. Auditor calculated the average amount reimbursed by MCR and noted an average MCR reimbursement rate of 26.8% and 28.1% in fiscal years 2021 and 2020, respectively. The calculated total of costs reimbursed by Medicare through the cost report is $1,062,184. Cause: The Organization lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete, agree to supporting spreadsheets, submitted timely, and properly maintained in the files of the Organization. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: No. Recommendation: We recommend the Organization evaluate its financial reporting processes and controls to determine whether additional controls over the preparation of any Provider Relief Fund reports are needed to ensure the reports are prepared in line with the Provider Relief Fund guidelines. Views of responsible officials: The Organization missed reducing the costs claimed against PRF by the amounts reimbursed through the Medicare cost report. The Organization did have additional lost revenues though that would offset these costs claimed and wouldn?t result in a repayment of the funds. We would look to HRSA for guidance on how you would like us to update our Phase 1 PRF report or how you would like to see this corrected. Also, the CFO will listen to webinars to receive education for Phase IV funds that were received by the Organization to ensure compliance with the reporting requirements.
Criteria or specific requirement: Per ?200.313, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal Award Identification Number (FAIN)), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Per the Organization's additions to Property and Equipment Policy, expenditures for tangible assets used actively in business operations with a cost exceeding $5,000 and with a useful life exceeding two years should be capitalized. Also per ?200.313, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: We noted the Organization is not in compliance with requirements related to the Equipment/Real Property Management of grants. Questioned costs: None. Context: During our testing, we noted the following exceptions: ? 1 out of 2 equipment samples totaling $13,306 was not capitalized and therefore not included in the either the departments fixed asset software or year end Property and Equipment financial balance. This asset was originally purchased in fiscal year 2021. As such, the auditor could not trace the equipment to a listing and properly identify the equipment through physical inspection. ? The organization did not complete the required 2 year physical inventory of equipment for 1 out of 1 federally purchased equipment. The equipment was originally purchased in June 2020. ? The Organization was not aware of the Equipment/Real Property Management CFR Requirements and lacks a process to ensure the Organization is in compliance with Equipment/Real Property Management CFR requirements. Cause: Management oversight; lack of effective internal controls addressing the purchase of equipment with Federal Funds. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-001 Recommendation: We recommend that the Organization create effective internal controls and procedures over the purchase of Federally Funded Equipment and Real Property and a tracking methodology to properly identify equipment purchased with federal funds that allows for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The Organization did have two purchases in FY21 that were expensed versus being capitalized. The Organization failed to follow the capital purchasing policy. The Organization has educated responsible parties of the capital purchasing policy to avoid future occurrences. The Organization has updated processes in fiscal year 2023 to ensure the purchasing policy is followed. The executive director of the program will conduct an annual physical inventory of federal purchased equipment.
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement and suspension and debarment. The Organization should have internal controls designed to ensure compliance with these provisions. Condition: We noted the Organization is not in compliance with requirements related to Procurement, Suspension and Debarment. Questioned costs: Unknown. Context: During our testing, we noted the following exceptions: ? The Organization?s procurement policy did not meet the requirements defined by 2 CFR 200. ? The Organization did not retain support to document the procurement methods followed (I.e., sole source, small purchases, sealed bids, proposals, etc.). ? For 7 out of 7 covered transactions, it was noted the Organization did not verify that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction. Cause: The Organization lacks a uniform Procurement, Suspension & Debarment policy that is in compliance with the Federal regulations and/or the terms and conditions of the Federal award. Effect: The auditor noted instances of noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients and/or vendors. Repeat Finding: Yes ? 2021-002. Recommendation: ? We recommend the Organization review and update its procurement policy to ensure the policy meets the 2 CFR Part 200 Procurement requirements. ? We recommend the Organization retain all documentation and support to show that the procurement policy was followed. ? We recommend the Organization review, update, and implement the current Suspension and Debarment Process as there is no currently defined process to complete the Suspension and Debarment checks prior to entering into a covered transaction. Views of responsible officials: The Organization was unaware of the need to have its policy include thresholds for purchases using federal funds. We will work with the responsible parties to develop a purchasing policy that meets the federal purchasing requirements. The Organization will adopt a procurement policy in fiscal year 2023. Also, vendors have been reviewed for suspension and debarment and a vendor log with the information was completed in fiscal year 2023.
Criteria or specific requirement: According to ?200.302 Financial management of 2 CFR Part 200, the non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must 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. Condition: We noted the Organization is not in compliance with requirements related to the reporting of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization did not complete the indirect costs section of the annual Federal Financial Report submitted during the fiscal year. Auditor noted a total of $74,062 was drawn in indirect costs for fiscal year 2022. ? The Organization is not reporting the action in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Cause: The Organization lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete, agree to supporting spreadsheets, submitted timely, and properly maintained in the files of the Organization. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: Yes ? 2021-003 Recommendation: ? We recommend the Organization review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete and timely. ? Specific to special reports for FFATA, we recommend the Organization provide training on the requirements to those employees responsible for reporting the action in FSRS. Views of responsible officials: The Organization was unaware of the FFATA reporting requirement. The Organization will register and submit the FFATA. Also, the Organization failed to report the indirect costs on the FFR. The Organization has notified the responsible parties to avoid future occurrences. The FFR?s have been completed to report indirect costs separately in fiscal year 2023. The FFATA was submitted in fiscal year 2023 and will be updated yearly.
Criteria or specific requirement: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. ? Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Condition: We noted the Organization is not in compliance with requirements related to the subrecipient monitoring of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization lacked a process to review the audits of subrecipients that would allow the Organization to identify any potential deficiencies that would require follow-up. ? The Organization lacked a process to complete a risk assessment that would allow the Organization to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Cause: The Organization does not have internal controls in place to ensure compliance with Federal regulations or the terms and conditions of the Federal award. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients. Repeat Finding: Yes ? 2021-004 Recommendation: We recommend that the Organization create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have since followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors and one as a subrecipient which is described below: ? Union County General Hospital (UCGH): Both ROAMS and UCGH see this relationship as a contractor. The stipend pays for a Tele-OB room in their facility and the budget even lists rent as part of the reason for the stipend. The stipend per the MoU also supports their participation in the monthly Governing Council meetings, data collection, IT support for the program implementation and decision making. ? Questa Health Center/Presbyterian Medical Services (Questa): Both ROAMS and Questa see this relationship as a contractor. The stipend pays for an OB room in their facility and is even listed as rent in the stipend budget. The stipend per the MoU also supports their participation in the monthly Governing Council and decision making. ? UNM Envision (UNM): UNM declared a portion of their stipend over the three-year period they received as subrecipient. They declared $39,635 as subrecipient and they received a total of $68,000 from ROAMS. ROAMS always saw the relationship as a contractor and not a subrecipient and we do not understand why they have declared a portion of their stipend as subrecipient. UNM was not an essential grant partner, joined in year two to assist with data review, participated in the Governing Council, and ROAMS has a data evaluation agreement with UNM that we understood as a contract. This different understanding of the relationships highlights the audit finding that the type of relationship should be agreed upon upfront. ? Miners Colfax Medical Center (MCMC): sees themselves as a subrecipient and we agree. They are a state hospital and the other Labor and Delivery hospital in the ROAMS grant, and like Holy Cross Medical Center have a very high data reporting burden and serve as the home for the patients. The Memorandum of Agreement signed by all Network partners outlines their obligations in section IV Provision of Services and VI Records and Information (a. b. and c.). As we have investigated the monitoring of subrecipients verses a contractor, we have found that the same follow up is necessary, as long as the subrecipient receives less than $750,000 in federal funds in a year, which is the case for MCMC. Our procedures for paying the stipend for both the contractors and one subrecipient (MCMC), have been attendance at the monthly Governing Council meetings, and deliverables from data collection, to IT support and meetings, workflow meetings, and clinical meetings. Reminders of deliverables that are pending are in the monthly Governing Council notes as is the attendance. ROAMS and the network partners were very clear in written documents and practice that the quarterly stipend payment was linked to participation and deliverables. We can provide you with monthly Governing Council notes to show this. A draft policy is in the works that will have the network partners formally declare their relationship as contractor or subrecipient and outline the monitoring of subrecipients. From our research we do not see the subrecipient monitoring being significantly different from a contractor unless the $750,000 threshold is met. The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors. The ROAMS Director will request from the entities the audits for the CFO review to review for deficiencies on an annual basis.
Criteria or specific requirement: According to ?200.302 Financial management of 2 CFR Part 200, the non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must 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. Condition: We noted the Organization is not in compliance with requirements related to the reporting of grants. Questioned costs: $1,062,184 Context: During our testing, we noted the following exception: ? The Organization did not reduce the PRF expenses claimed by the amounts reimbursed by Medicare through the cost report. Auditor calculated the average amount reimbursed by MCR and noted an average MCR reimbursement rate of 26.8% and 28.1% in fiscal years 2021 and 2020, respectively. The calculated total of costs reimbursed by Medicare through the cost report is $1,062,184. Cause: The Organization lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete, agree to supporting spreadsheets, submitted timely, and properly maintained in the files of the Organization. Effect: The auditor noted instances of noncompliance. Noncompliance can result in delayed reimbursement of eligible Federal expenditures or potential loss of Federal funding. Repeat Finding: No. Recommendation: We recommend the Organization evaluate its financial reporting processes and controls to determine whether additional controls over the preparation of any Provider Relief Fund reports are needed to ensure the reports are prepared in line with the Provider Relief Fund guidelines. Views of responsible officials: The Organization missed reducing the costs claimed against PRF by the amounts reimbursed through the Medicare cost report. The Organization did have additional lost revenues though that would offset these costs claimed and wouldn?t result in a repayment of the funds. We would look to HRSA for guidance on how you would like us to update our Phase 1 PRF report or how you would like to see this corrected. Also, the CFO will listen to webinars to receive education for Phase IV funds that were received by the Organization to ensure compliance with the reporting requirements.