Audit 43782

FY End
2022-12-31
Total Expended
$13.01M
Findings
2
Programs
9
Organization: St. John's Riverside Hospital (NY)
Year: 2022 Accepted: 2023-09-28
Auditor: Kpmg LLP

Organization Exclusion Status:

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Contacts

Name Title Type
SECKG75HMKR1 Brian Behr Auditee
9149644431 Maria Tiso Auditor
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Notes to SEFA

Title: Loan/loan guarantee outstanding balances Accounting Policies: (1) Basis of Presentation The accompanying Schedule of expenditures of Federal Awards (the Schedule) includes the federal award activity of St. Johns Riverside Hospital and Subsidiary (the Hospital) under programs of the federal government. The information in this 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 (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Hospital, it is not intended to and does not present the financial position, changes in net assets (deficit), or cash flows of the Hospital.(3) Summary of Significant Accounting Policies Expenditures reported on the Schedule of expenditures of Federal Awards are reported on the accrual basis of accounting, except for the following grants: ? COVID-19 Testing for the Uninsured (Federal assistance listing number 93.461) is presented based on the date of service performed on or prior to December 31, 2022 for the eligible patients verified by the U.S. Department of Health and Human Services.? COVID-19 PRF and ARP Rural Distribution (Federal assistance listing number 93.498) represents the total expenditures and/or lost revenues from the Period 3 and Period 4 report submissions to the PRF Reporting Portal. Period 3 is based on payments received from January 1, 2021 through June 30, 2021, with a period of availability of expenses and/or lost revenues from January 1, 2020 through June 30, 2022. Period 4 is based on payments received from July 1, 2021 to December 31, 2021, with a period of availability of expenses and/or lost revenues from January 1, 2020 through December 31, 2022. Any unused expenditures and/or lost revenues from any previous periods may be applied for funds.? Grants presented based on the reimbursement amount approved by the U.S. Department of Health and Human Services and cash drawdowns during January 1, 2022 to December 31, 2022. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (Federal assistance listing number 93.918) COVID-19 Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (Federal assistance listing number 93.918)The expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule, if any, represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Hospital has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. With respect to the Federal Direct Student Loans Program, the Hospital is only responsible for the performance of certain administrative duties; therefore, the transactions and the balances of loans outstanding related to this program are not included in the Hospitals consolidated financial statements. The Schedule of Expenditures of Federal Awards includes the amounts loaned to students during the year ended December 31, 2022. It is not practical to estimate the outstanding balance of loans under this program.
Title: Pass-through to Subrecipients Accounting Policies: (1) Basis of Presentation The accompanying Schedule of expenditures of Federal Awards (the Schedule) includes the federal award activity of St. Johns Riverside Hospital and Subsidiary (the Hospital) under programs of the federal government. The information in this 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 (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Hospital, it is not intended to and does not present the financial position, changes in net assets (deficit), or cash flows of the Hospital.(3) Summary of Significant Accounting Policies Expenditures reported on the Schedule of expenditures of Federal Awards are reported on the accrual basis of accounting, except for the following grants: ? COVID-19 Testing for the Uninsured (Federal assistance listing number 93.461) is presented based on the date of service performed on or prior to December 31, 2022 for the eligible patients verified by the U.S. Department of Health and Human Services.? COVID-19 PRF and ARP Rural Distribution (Federal assistance listing number 93.498) represents the total expenditures and/or lost revenues from the Period 3 and Period 4 report submissions to the PRF Reporting Portal. Period 3 is based on payments received from January 1, 2021 through June 30, 2021, with a period of availability of expenses and/or lost revenues from January 1, 2020 through June 30, 2022. Period 4 is based on payments received from July 1, 2021 to December 31, 2021, with a period of availability of expenses and/or lost revenues from January 1, 2020 through December 31, 2022. Any unused expenditures and/or lost revenues from any previous periods may be applied for funds.? Grants presented based on the reimbursement amount approved by the U.S. Department of Health and Human Services and cash drawdowns during January 1, 2022 to December 31, 2022. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (Federal assistance listing number 93.918) COVID-19 Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (Federal assistance listing number 93.918)The expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule, if any, represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Hospital has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Hospital did not provide federal awards to subrecipients in 2022.
Title: 2022 PROGRAM EXPENDITURES INCURRED IN PRIOR YEARS Accounting Policies: (1) Basis of Presentation The accompanying Schedule of expenditures of Federal Awards (the Schedule) includes the federal award activity of St. Johns Riverside Hospital and Subsidiary (the Hospital) under programs of the federal government. The information in this 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 (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Hospital, it is not intended to and does not present the financial position, changes in net assets (deficit), or cash flows of the Hospital.(3) Summary of Significant Accounting Policies Expenditures reported on the Schedule of expenditures of Federal Awards are reported on the accrual basis of accounting, except for the following grants: ? COVID-19 Testing for the Uninsured (Federal assistance listing number 93.461) is presented based on the date of service performed on or prior to December 31, 2022 for the eligible patients verified by the U.S. Department of Health and Human Services.? COVID-19 PRF and ARP Rural Distribution (Federal assistance listing number 93.498) represents the total expenditures and/or lost revenues from the Period 3 and Period 4 report submissions to the PRF Reporting Portal. Period 3 is based on payments received from January 1, 2021 through June 30, 2021, with a period of availability of expenses and/or lost revenues from January 1, 2020 through June 30, 2022. Period 4 is based on payments received from July 1, 2021 to December 31, 2021, with a period of availability of expenses and/or lost revenues from January 1, 2020 through December 31, 2022. Any unused expenditures and/or lost revenues from any previous periods may be applied for funds.? Grants presented based on the reimbursement amount approved by the U.S. Department of Health and Human Services and cash drawdowns during January 1, 2022 to December 31, 2022. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (Federal assistance listing number 93.918) COVID-19 Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (Federal assistance listing number 93.918)The expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule, if any, represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Hospital has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. During the year ended December 31, 2022, the U.S. Department of Homeland Security passed federal funding to the Hospital through the Federal Emergency Managerial Agency (FEMA) totaling $9,776,731 for various project expenditures that were incurred in prior years.

Finding Details

Criteria In accordance with the Federal Emergency Management Agency (FEMA) Public Assistance Program and Policy Guide, version 2.1, Chapter 2: V.P., costs are not eligible for reimbursement if an entity received funding from another source (i.e. patient revenue, insurance, etc.) for the same work that FEMA funded. This is referred to by FEMA as ?duplication of benefits?. Additionally, FEMA issued a Memorandum on February 15, 2023, titled ?Hypothetical Reasonable Applicant Methods? that illustrates the basic elements of a method for accounting for (estimating) the amount of duplication of benefits within net patient service revenue. Condition and Context In July 2023, the Hospital received an Applicant Review Memo from the Homeland Security Operational Analysis Center (HSOAC) that it has conducted a review for duplication of benefits and summarizing a recommendation for the reduction of the Hospital?s COVID-19 Public Assistance (PA) equipment expenditures within previously obligated FEMA projects, in the amount of $1.2 million. The amount in question was derived from a calculation provided by the HSOAC, which determined a disallowable threshold percentage of equipment using the Hospital?s most recent pre-pandemic year (2019) and calculating a proportion of equipment expenses to total patient care revenue. This threshold percentage is then multiplied by total patient care revenue for the fiscal years ending December 31, 2020 and 2021, respectively, to determine the potential disallowable costs. The Hospital believes that there has been no duplication of benefits based on the use of an alternative methodology. The Hospital intends to appeal the disallowed costs. Based on the fact that FEMA allows for alternative methods to calculate the potential duplication of benefits amount and the lack of clarity of what constitutes a ?Hypothetical Reasonable Applicant Method? in the FEMA guidance, we are unable to obtain sufficient and appropriate audit evidence as to whether the disallowed costs of $1.2 million are allowable. Questioned costs Cannot be determined. Statistical Sample Not applicable Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Hospital work with FEMA to identify an acceptable methodology to calculate (estimate) the amount (if any) of the duplication of benefits. Additionally, we also recommend the Hospital follow the FEMA appeals process to resolve their disagreement of the disallowed (deobligated) costs. View of Responsible Official Management agrees with the auditor?s recommendation and will work with FEMA to identify an acceptable methodology to calculate if any duplication of benefits. The Hospital will also appeal the disallowed costs presented by FEMA.
Criteria In accordance with the Federal Emergency Management Agency (FEMA) Public Assistance Program and Policy Guide, version 2.1, Chapter 2: V.P., costs are not eligible for reimbursement if an entity received funding from another source (i.e. patient revenue, insurance, etc.) for the same work that FEMA funded. This is referred to by FEMA as ?duplication of benefits?. Additionally, FEMA issued a Memorandum on February 15, 2023, titled ?Hypothetical Reasonable Applicant Methods? that illustrates the basic elements of a method for accounting for (estimating) the amount of duplication of benefits within net patient service revenue. Condition and Context In July 2023, the Hospital received an Applicant Review Memo from the Homeland Security Operational Analysis Center (HSOAC) that it has conducted a review for duplication of benefits and summarizing a recommendation for the reduction of the Hospital?s COVID-19 Public Assistance (PA) equipment expenditures within previously obligated FEMA projects, in the amount of $1.2 million. The amount in question was derived from a calculation provided by the HSOAC, which determined a disallowable threshold percentage of equipment using the Hospital?s most recent pre-pandemic year (2019) and calculating a proportion of equipment expenses to total patient care revenue. This threshold percentage is then multiplied by total patient care revenue for the fiscal years ending December 31, 2020 and 2021, respectively, to determine the potential disallowable costs. The Hospital believes that there has been no duplication of benefits based on the use of an alternative methodology. The Hospital intends to appeal the disallowed costs. Based on the fact that FEMA allows for alternative methods to calculate the potential duplication of benefits amount and the lack of clarity of what constitutes a ?Hypothetical Reasonable Applicant Method? in the FEMA guidance, we are unable to obtain sufficient and appropriate audit evidence as to whether the disallowed costs of $1.2 million are allowable. Questioned costs Cannot be determined. Statistical Sample Not applicable Repeat Finding A similar finding was not reported in the prior year audit. Recommendation We recommend the Hospital work with FEMA to identify an acceptable methodology to calculate (estimate) the amount (if any) of the duplication of benefits. Additionally, we also recommend the Hospital follow the FEMA appeals process to resolve their disagreement of the disallowed (deobligated) costs. View of Responsible Official Management agrees with the auditor?s recommendation and will work with FEMA to identify an acceptable methodology to calculate if any duplication of benefits. The Hospital will also appeal the disallowed costs presented by FEMA.