Audit 46954

FY End
2022-12-31
Total Expended
$1.49M
Findings
2
Programs
7
Year: 2022 Accepted: 2023-08-15

Organization Exclusion Status:

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Contacts

Name Title Type
S9ZLWKBUKN28 John Rusnaczyk Auditee
2163637718 Jordan Pace Auditor
No contacts on file

Notes to SEFA

Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of St. Vincent Charity Medical Center and Subsidiaries (the System) under programs of the federal government for the year ended December 31, 2022. 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). Because the Schedule presents only a selected portion of the operations of the System, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the System. Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement, , except for expenditures related to Assistance Listing Number (ALN) 93.498, Provider Relief Fund and American Rescue Plan Rural Distribution (PRF). PRF does not apply the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, but rather applies the U.S. Department of Health and Human Services guidance and frequently asked questions, as outlined in the Compliance Supplement. For the PRF program, HHS has indicated that the amounts on the Schedule should be reported in correspondence with reporting requirements of the HHS PRF Reporting Portal. Payments from HHS for PRF are assigned a payment received period based upon the date of each payment from PRF was received. Each period has a specified period of availability and timing of reporting requirements. The pass-through entity identifying numbers are presented where available. The System has elected not to use the 10 percent de minimis indirect cost rate to recover indirect costs, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

2022-001 ALN, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19: Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds (PRF), the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS October 2022, post- payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Condition - The System had a control to review the reporting information under this award, however, the control was ineffective and resulted in incorrect determination of lost revenue reported in required portal submission of such information. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Lost revenue reported in the PRF portal revealed an overstatement of approximately $5.1 million of lost revenue reported for Period 4. One of the System's subsidiaries, St. Vincent Medical Group, received targeted distributions and reported their respective lost revenue at both the subsidiary and parent level. The aggregate lost revenue reported should have been approximately $18,000 in comparison to $5,100,000 reported. Cause and Effect - The System designed controls related to identification of allowable lost revenue to be entered into the portal for submission to HHS, which included a review of the final lost revenue calculation; however, the review process did not effectively identify lost revenue for targeted distributions that was reported on St. Vincent Medical Group's portal submission and therefore should have been deducted from the amount of lost revenue that was reported on the System portal submission. The failure to have an effective control in place caused the System to overstate the amount of the actual lost revenue available for use in the Period 4 portal submissions. Recommendation - We recommend that the review process include specific procedures to ensure that lost revenue amounts have not been included more than once and that the lost revenue reported in the portal submission follows the guidance provided by the HHS. Further, we recommend that the lost revenue calculation be updated in the next available portal submission. Views of Responsible Officials and Corrective Action Plan - Chief Financial Officer will ensure that all guidance available for PRF reporting is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions.
2022-001 ALN, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19: Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds (PRF), the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS October 2022, post- payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Condition - The System had a control to review the reporting information under this award, however, the control was ineffective and resulted in incorrect determination of lost revenue reported in required portal submission of such information. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Lost revenue reported in the PRF portal revealed an overstatement of approximately $5.1 million of lost revenue reported for Period 4. One of the System's subsidiaries, St. Vincent Medical Group, received targeted distributions and reported their respective lost revenue at both the subsidiary and parent level. The aggregate lost revenue reported should have been approximately $18,000 in comparison to $5,100,000 reported. Cause and Effect - The System designed controls related to identification of allowable lost revenue to be entered into the portal for submission to HHS, which included a review of the final lost revenue calculation; however, the review process did not effectively identify lost revenue for targeted distributions that was reported on St. Vincent Medical Group's portal submission and therefore should have been deducted from the amount of lost revenue that was reported on the System portal submission. The failure to have an effective control in place caused the System to overstate the amount of the actual lost revenue available for use in the Period 4 portal submissions. Recommendation - We recommend that the review process include specific procedures to ensure that lost revenue amounts have not been included more than once and that the lost revenue reported in the portal submission follows the guidance provided by the HHS. Further, we recommend that the lost revenue calculation be updated in the next available portal submission. Views of Responsible Officials and Corrective Action Plan - Chief Financial Officer will ensure that all guidance available for PRF reporting is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions.