Audit 45038

FY End
2022-12-31
Total Expended
$14.10M
Findings
2
Programs
3
Organization: Emanate Health and Affiliates (CA)
Year: 2022 Accepted: 2023-09-24

Organization Exclusion Status:

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Contacts

Name Title Type
JQEQAP9VKZS8 Leon Choiniere Auditee
6269387595 Scott Enos Auditor
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Notes to SEFA

Title: Nature of Activities Accounting Policies: 1. Summary of Significant Accounting Policies: Basis of Accounting: The accompanying schedule of expenditures of federal awards (the SEFA) includes the federal award activity of Emanate Health and Affiliates under programs of the federal government for the year ended December 31, 2022. The information in the SEFA is presented in accordance with the requirements of the provisions 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 SEFA presents only a selected portion of the operations of Emanate Health and Affiliates, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Emanate Health and Affiliates. Expenditures reported on the SEFA are reported on the accrual basis of accounting. Such 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. Therefore, some amounts presented in the SEFA may differ from amounts presented in, or used in the preparation of, the financial statements. The SEFA does not include payments received under the traditional Medicare and Medicaid reimbursement programs, as these programs are outside the scope of the Uniform Guidance. There were no donated goods and personal protective equipment received from federal sources that required recognition or disclosure in the notes to the SEFA. De Minimis Rate Used: N Rate Explanation: 2. Indirect Costs: Emanate Health and Affiliates has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. 3. Nature of Activities: Emanate Health and Affiliates receives grants to cover costs of specified programs. Final determination of eligibility of costs will be made by the grantors. Should any costs be found ineligible, Emanate Health and Affiliates will be responsible for reimbursing the grantors for these amounts. Additionally, expenditures incurred for various programs may exceed the amounts awarded from the respective federal agency. The amounts reported on the SEFA are limited to the award amounts. Amounts in excess of this amount are paid out of non-federal sources.
Title: Provider Relief Fund Accounting Policies: 1. Summary of Significant Accounting Policies: Basis of Accounting: The accompanying schedule of expenditures of federal awards (the SEFA) includes the federal award activity of Emanate Health and Affiliates under programs of the federal government for the year ended December 31, 2022. The information in the SEFA is presented in accordance with the requirements of the provisions 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 SEFA presents only a selected portion of the operations of Emanate Health and Affiliates, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Emanate Health and Affiliates. Expenditures reported on the SEFA are reported on the accrual basis of accounting. Such 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. Therefore, some amounts presented in the SEFA may differ from amounts presented in, or used in the preparation of, the financial statements. The SEFA does not include payments received under the traditional Medicare and Medicaid reimbursement programs, as these programs are outside the scope of the Uniform Guidance. There were no donated goods and personal protective equipment received from federal sources that required recognition or disclosure in the notes to the SEFA. De Minimis Rate Used: N Rate Explanation: 2. Indirect Costs: Emanate Health and Affiliates has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. 4. Provider Relief Fund: The amount presented on the SEFA for Assistance Listing Number 93.498, COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF Funds) is for the year ended December 31, 2022. The amount presented reconciles to the Provider Relief Fund (PRF) information reported to the Health Resources and Services Administration (HRSA) as follows: See the Notes to the SEFA for table. Health and Human Services (HHS) has indicated the PRF Funds on the SEFA be reported corresponding to reporting requirements of the HRSA PRF Reporting Portal. Payments from HHS for PRF are assigned to Payment Received Periods (each, a Period) based upon the date each payment from the PRF was received. Each Period has a specified Period of Availability and timing of reporting requirements. Entities report into the HRSA PRF Reporting Portal after each Periods deadline to use the funds (i.e., after the end of the Period of Availability). The SEFA includes $2,119,082 of PRF Funds received from HHS between January 1, 2021 through December 31, 2021. In accordance with guidance from HHS, these amounts are presented as Period 3 and Period 4. Such amounts were recognized as Provider relief fund in Emanate Health and Affiliates financial statements in the year ended December 31, 2021.
Title: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Accounting Policies: 1. Summary of Significant Accounting Policies: Basis of Accounting: The accompanying schedule of expenditures of federal awards (the SEFA) includes the federal award activity of Emanate Health and Affiliates under programs of the federal government for the year ended December 31, 2022. The information in the SEFA is presented in accordance with the requirements of the provisions 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 SEFA presents only a selected portion of the operations of Emanate Health and Affiliates, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Emanate Health and Affiliates. Expenditures reported on the SEFA are reported on the accrual basis of accounting. Such 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. Therefore, some amounts presented in the SEFA may differ from amounts presented in, or used in the preparation of, the financial statements. The SEFA does not include payments received under the traditional Medicare and Medicaid reimbursement programs, as these programs are outside the scope of the Uniform Guidance. There were no donated goods and personal protective equipment received from federal sources that required recognition or disclosure in the notes to the SEFA. De Minimis Rate Used: N Rate Explanation: 2. Indirect Costs: Emanate Health and Affiliates has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. 5. Disaster Grants Public Assistance (Presidentially Declared Disasters): In accordance with guidance from the U.S. Department of Homeland Security, the amount presented on the SEFA for Assistance Listing Number 97.036 COVID-19 Disaster Grants Public Assistance (Presidentially Declared Disasters), represents expenditures that were incurred as of the end of the fiscal year, related to project worksheets approved by the Federal Emergency Management Agency (FEMA) during the fiscal year. Emanate Health and Affiliates recognized $11,860,677 in COVID-19 related funding from FEMA during the fiscal year ended December 31, 2022 through a subaward from the California Governors Office of Emergency Services. Of this amount, $11,860,677 in expenditures were incurred prior to the beginning of the fiscal year.

Finding Details

Finding 2022-001: Internal control deficiency and noncompliance over the calculation of lost revenues attributable to coronavirus. Identification of the federal program: Assistance Listing Number 93.498: ? COVID-19 ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? U.S. Department of Health and Human Services ? Federal award identification number ? Not Applicable ? Federal award year: o Period 3 ? January 1, 2020 to June 30, 2022 o Period 4 ? January 1, 2020 to December 31, 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 ? Internal controls. 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). The terms and conditions of the award requires the following: ? The recipient shall adhere to the reporting requirements on provider relief fund payments for payments received exceeding $10,000 in the aggregate during the payment received period. The recipient must register in the provider relief fund reporting portal and submit reports as specified by HHS. ? The recipient certifies that all information it provides as part of any application for the payment, as well as all information and reports relating to the payment that it provides in the future at the request of HHS or the HHS inspector general, are true, accurate and complete, to the best of its knowledge. ? The recipient shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR 75.302 ? financial management and 45 CFR 75.361 through 75.365 ? record retention and access, and other information required by future program instructions to substantiate the reimbursement of costs under this award. Condition: Emanate Health and Affiliates incorrectly reported lost revenues attributable to coronavirus in the HRSA PRF Reporting Portal (the ?Portal?) due to errors made in the calculation of lost revenues which resulted in an overstatement of lost revenues of $8,123,440. Cause: Management did not have effective internal controls in place to ensure the reported lost revenues attributable to coronavirus reported in the Portal were calculated according to terms and conditions of the award and free from error. Effect or potential effect: The calculation of lost revenues attributable to coronavirus was reported incorrectly in the Portal which resulted in an overstatement of lost revenues of $8,123,440. Questioned costs: None. Context: During our testing over reporting, we obtained a listing of 3 PRF reports submitted to the Portal and selected 2 PRF reports for testing. We observed the calculation of lost revenues incorrectly excluded hospital fee revenues in 2022 actuals but did include hospital fee revenues in 2019 actuals resulting in the comparison of actuals to actuals under the option 1 method to be performed on a non-comparable basis (as the entity should include the same types of revenues in both years being compared). This resulted in an overstatement of lost revenues of $8,123,440. After taking the errors into consideration, Emanate Health and Affiliates still had excess lost revenues to substantiate the payments received. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management develop and implement effective internal controls to ensure accurate reporting in the Portal in accordance with terms and conditions of the award. This will ensure the calculation of lost revenues attributable to coronavirus is reported correctly. Views of responsible officials: In future reporting periods, management will add an additional layer of review of the lost revenue calculation before submission through the Portal. Through this review, management will ensure the lost revenue calculation is performed on a comparable basis which would include the same types of revenues being compared. Management will correct the lost revenues attributable to coronavirus in the next Portal submission, as applicable and ensure any other Portal submissions have the correct lost revenue calculation and is reported correctly.
Finding 2022-001: Internal control deficiency and noncompliance over the calculation of lost revenues attributable to coronavirus. Identification of the federal program: Assistance Listing Number 93.498: ? COVID-19 ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? U.S. Department of Health and Human Services ? Federal award identification number ? Not Applicable ? Federal award year: o Period 3 ? January 1, 2020 to June 30, 2022 o Period 4 ? January 1, 2020 to December 31, 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A, Chapter II, Part 200, Subpart D, 200.303 ? Internal controls. 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). The terms and conditions of the award requires the following: ? The recipient shall adhere to the reporting requirements on provider relief fund payments for payments received exceeding $10,000 in the aggregate during the payment received period. The recipient must register in the provider relief fund reporting portal and submit reports as specified by HHS. ? The recipient certifies that all information it provides as part of any application for the payment, as well as all information and reports relating to the payment that it provides in the future at the request of HHS or the HHS inspector general, are true, accurate and complete, to the best of its knowledge. ? The recipient shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR 75.302 ? financial management and 45 CFR 75.361 through 75.365 ? record retention and access, and other information required by future program instructions to substantiate the reimbursement of costs under this award. Condition: Emanate Health and Affiliates incorrectly reported lost revenues attributable to coronavirus in the HRSA PRF Reporting Portal (the ?Portal?) due to errors made in the calculation of lost revenues which resulted in an overstatement of lost revenues of $8,123,440. Cause: Management did not have effective internal controls in place to ensure the reported lost revenues attributable to coronavirus reported in the Portal were calculated according to terms and conditions of the award and free from error. Effect or potential effect: The calculation of lost revenues attributable to coronavirus was reported incorrectly in the Portal which resulted in an overstatement of lost revenues of $8,123,440. Questioned costs: None. Context: During our testing over reporting, we obtained a listing of 3 PRF reports submitted to the Portal and selected 2 PRF reports for testing. We observed the calculation of lost revenues incorrectly excluded hospital fee revenues in 2022 actuals but did include hospital fee revenues in 2019 actuals resulting in the comparison of actuals to actuals under the option 1 method to be performed on a non-comparable basis (as the entity should include the same types of revenues in both years being compared). This resulted in an overstatement of lost revenues of $8,123,440. After taking the errors into consideration, Emanate Health and Affiliates still had excess lost revenues to substantiate the payments received. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management develop and implement effective internal controls to ensure accurate reporting in the Portal in accordance with terms and conditions of the award. This will ensure the calculation of lost revenues attributable to coronavirus is reported correctly. Views of responsible officials: In future reporting periods, management will add an additional layer of review of the lost revenue calculation before submission through the Portal. Through this review, management will ensure the lost revenue calculation is performed on a comparable basis which would include the same types of revenues being compared. Management will correct the lost revenues attributable to coronavirus in the next Portal submission, as applicable and ensure any other Portal submissions have the correct lost revenue calculation and is reported correctly.