Audit 43301

FY End
2022-12-31
Total Expended
$26.73M
Findings
2
Programs
9
Year: 2022 Accepted: 2023-09-25
Auditor: Ernst & Young

Organization Exclusion Status:

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Contacts

Name Title Type
CTKLWXNABFS5 Elaine Debuona Auditee
5167051935 Joan Palermo Auditor
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Notes to SEFA

Title: Categorization of Expenditures Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal grant activity of Catholic Health (CH) and is prepared on the accrual basis of accounting. The information in the Schedule 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 (the Uniform Guidance). For purposes of the Schedule, 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 noncash assistance. In accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of Catholic Health.Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX for awards subject to the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Schedule reflects federal expenditures for all individual grants that were active during the year. The categorization of expenditures by program included in the Schedule is based on the Assistance Listings. Changes in the categorization of expenditures occur based on revisions to the Assistance Listings, which are issued periodically.
Title: COVID 19 Provider Relief Fund and American Rescue Plan Rural Distribution Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal grant activity of Catholic Health (CH) and is prepared on the accrual basis of accounting. The information in the Schedule 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 (the Uniform Guidance). For purposes of the Schedule, 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 noncash assistance. In accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Note 4). Therefore, some amounts presented in the Schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements of Catholic Health.Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX for awards subject to the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. In accordance with the U.S. Department of Health and Human Services requirements specific to Federal Assistance Listing Number 93.498, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, the amount presented on the Schedule for the year ended December 31, 2022, for Federal Assistance Listing Number 93.498, relates to Provider Relief Fund (PRF) and ARP payments received from January 1, 2021 through December 31, 2021, used for lost revenues and health care related expenses for the period January 1, 2020 through December 31, 2022. The amounts presented reconcile to the PRF information previously reported to the Health Resources and Services Administration (HRSA) for PRF Reporting Periods 3 and 4. The PRF payments for 2022 total $13,920,453. The health care related expenses and lost revenues incurred attributable to Coronavirus Disease 2019 (COVID 19) during the period of availability for PRF Reporting Period 3 (January 1, 2020 through June 30, 2022) and PRF Reporting Period 4 (January 1, 2020 through December 31, 2022) are in excess of the distributions received from April 10, 2020 through December 31, 2021 and, therefore, the amounts presented in the table above and on the accompanying Schedule are limited to the amount of such distributions. CH also received PRF payments subsequent to December 31, 2021, which are required to be reported in subsequent HRSA PRF Reporting Periods and, accordingly, pursuant to the requirements specific to Federal Assistance Listing Number 93.498, activity related to such payments is excluded from the accompanying Schedule.

Finding Details

Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: COVID 19 ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing No.: 93.498 Criteria or Specific Requirement: The terms and conditions of the Provider Relief Fund (PRF) award requires the recipient to submit reports as the secretary of the United States Department of Health and Human Services (HHS) determines are needed to ensure compliance with conditions that are imposed on the award, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: Other PRF expenses for payment received during payment period July 1, 2021 to December 31, 2021 were unintentionally included when reporting in the Health Resources and Services Administration PRF Reporting Portal (the Portal) for Catholic Health?s (Parent entity ? TIN #11-3403968) Reporting Period 4 Portal submission; the same expense amount was previously reported on the Reporting Period 3 Portal submission. The PRF Reporting Period 4 submission was intended to attribute only lost revenues to the payments received for the Period 4 timeframe, as documented in the lost revenue alternate methodology narrative prepared and included in the Period 4 Portal submission. Cause: A control was performed to review the report submission and confirm details in the report were prepared in accordance with the documented narrative around lost revenues and reporting methodology. However, the review was not precise enough to detect the inclusion of an expense amount attributable to Coronavirus that was not intended to be included in the report. Effect or Potential Effect: This resulted in an unintentional inclusion of an amount of eligible expenses reported within CH?s PRF Reporting Period 4 submission (July 1, 2022 to December 31, 2022) that was previously included in the Reporting Period 3 submission, when the intention of the PRF Reporting Period 4 submission was to only include lost revenues to attribute to the funding received. As such, the documentation included in the Portal is inconsistent with the Portal submission fields. Questioned Costs: None. Context: During our testing over the Reporting compliance requirement, we obtained the PRF Portal submissions for Reporting Period 3 and Reporting Period 4 for the Parent entity (TIN #11-3403968). We observed the same amount of eligible expenses included in the Reporting Period 3 Portal submission of $773,727 was also included in the Reporting Period 4 Portal submission. While inclusion of these expenses resulted in unintended reporting of eligible expenses in the Portal submission, the amount of lost revenues reported and carried forward from Reporting Period 3 was in excess of the Provider Relief Funding received. As such, there is no impact on meeting the requirements to retain the funding received as eligible expenses and lost revenues attributable to Coronavirus significantly exceeded the Provider Relief Funds received. Recommendation: We recommend that management refine the precision of its control to ensure accurate reporting in the Portal. Views of Responsible Officials: Management concurs with this finding. Management has refined its controls to ensure that there are multiple levels of review of all documentation included in the Portal, as well as review of the Portal input to ensure it is consistent with the supporting documentation.
Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: COVID 19 ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing No.: 93.498 Criteria or Specific Requirement: The terms and conditions of the Provider Relief Fund (PRF) award requires the recipient to submit reports as the secretary of the United States Department of Health and Human Services (HHS) determines are needed to ensure compliance with conditions that are imposed on the award, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: Other PRF expenses for payment received during payment period July 1, 2021 to December 31, 2021 were unintentionally included when reporting in the Health Resources and Services Administration PRF Reporting Portal (the Portal) for Catholic Health?s (Parent entity ? TIN #11-3403968) Reporting Period 4 Portal submission; the same expense amount was previously reported on the Reporting Period 3 Portal submission. The PRF Reporting Period 4 submission was intended to attribute only lost revenues to the payments received for the Period 4 timeframe, as documented in the lost revenue alternate methodology narrative prepared and included in the Period 4 Portal submission. Cause: A control was performed to review the report submission and confirm details in the report were prepared in accordance with the documented narrative around lost revenues and reporting methodology. However, the review was not precise enough to detect the inclusion of an expense amount attributable to Coronavirus that was not intended to be included in the report. Effect or Potential Effect: This resulted in an unintentional inclusion of an amount of eligible expenses reported within CH?s PRF Reporting Period 4 submission (July 1, 2022 to December 31, 2022) that was previously included in the Reporting Period 3 submission, when the intention of the PRF Reporting Period 4 submission was to only include lost revenues to attribute to the funding received. As such, the documentation included in the Portal is inconsistent with the Portal submission fields. Questioned Costs: None. Context: During our testing over the Reporting compliance requirement, we obtained the PRF Portal submissions for Reporting Period 3 and Reporting Period 4 for the Parent entity (TIN #11-3403968). We observed the same amount of eligible expenses included in the Reporting Period 3 Portal submission of $773,727 was also included in the Reporting Period 4 Portal submission. While inclusion of these expenses resulted in unintended reporting of eligible expenses in the Portal submission, the amount of lost revenues reported and carried forward from Reporting Period 3 was in excess of the Provider Relief Funding received. As such, there is no impact on meeting the requirements to retain the funding received as eligible expenses and lost revenues attributable to Coronavirus significantly exceeded the Provider Relief Funds received. Recommendation: We recommend that management refine the precision of its control to ensure accurate reporting in the Portal. Views of Responsible Officials: Management concurs with this finding. Management has refined its controls to ensure that there are multiple levels of review of all documentation included in the Portal, as well as review of the Portal input to ensure it is consistent with the supporting documentation.