Finding 2022-002 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Allowable Costs Questioned Cost: $406,035 (Known Questioned Cost) Condition: In Provider Relief Fund reporting period 2, the Moore Center Services, Inc. reported expenditures of $406,035 related to an HVAC capital project that was not yet complete and placed into service by the end of the period of availability, of December 31, 2021. Criteria: The Provider Relief Fund Frequently Asked Questions (FAQs) state ?For projects that are a bundle of services and purchases of tangible items that cannot be separated, such as capital projects, construction projects, or alteration and renovation projects, the project costs cannot be reimbursed using Provider Relief Fund payments unless the project was fully completed by the end of the Period of Availability associated with the Payment Received Period.? This language was added to the FAQs, on August 30, 2021. Section III ? Federal Award Findings (Continued) Cause: The Provider Relief Fund Post-Payment Notice of Reporting Requirements state that updates to HVAC systems are an allowable use of the funds. The Agency began discussions of the HVAC project in Spring 2021, and entered into an agreement with a contractor during October 2021 and work on the project commenced in April 2022, but the project was not fully completed by the end of the Period of Availability (December 31, 2021) as required by the Provider Relief Fund FAQs. Effect: Expenditures for a capital project that was not complete by the end of the Period of Availability, were claimed in reporting period 2, which has resulted in a reportable finding. Recommendation: Management should implement procedures to ensure grant funds are expended on allowable costs during the applicable periods of availability. View of Responsible Officials: The Agency began discussions of the need for on HVAC update in the Spring of 2021. After receiving various proposals, the Agency entered into an agreement in October 2021 for an HVAC update. According to the Post-Payment Notice of Reporting Requirements HVAC updates are considered to be an allowable cost. The Agency relied on FAQ dated July 15, 2021, during their planning of the capital expenditure, which did not include a requirement that the capital project be fully complete by the end of the Period of Availability to be allowable. This requirement was added on August 30, 2021. The FAQ the Agency referred to, stated ?For purchases of tangible items made using Provider Relief Funds payments, the purchase does not need to be in the Reporting Entity?s possession (i.e. backordered personal protective equipment, capital equipment) to be considered an eligible expense.? HVAC projects at facilities require a significant amount of time to plan, design, and build under normal circumstances, even before taking into consideration complications added by the pandemic, which included contractor shortages, labor availability issues, and supply chain issues. The Agency in good faith, started the process of receiving bids for the project, entered into the contract, and committed funds to the project, using the guidance available at the time of the commitment. The project was part of the Agency?s initiative to prevent, prepare for, and respond to coronavirus and, accordingly, the Provider Relief Fund grants were used to help fund the initiative.
Finding 2022-003 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Internal Control, Significant Deficiency Compliance Requirement: Allowable Costs Questioned Cost: $0 Condition: In Provider Relief Fund reporting period 2, Moore Center Services, Inc., reported expenditures of $210,729 for insurance policy premium payments for the policy period of July 1, 2021 to June 30, 2022. Under GAAP accrual accounting, the insurance policy premiums would be amortized over the policy period of July 1, 2021 to June 30, 2022, resulting in 6 months of ineligible expense outside the period of availability ending December 31, 2021. Criteria: The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. The Provider Relief Fund Frequently Asked Questions (FAQs) state: ?Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.? Cause: The Provider Relief Fund Post-Payment Notice of Reporting Requirements states that premiums paid for property, malpractice, business insurance, or other insurance relevant to operations are an allowable expense. Therefore, the Agency applied the insurance premiums paid prior to the end of the period of availability of December 31, 2021 to the funding. However, the Agency, did not take into account the accrual basis of accounting for the expenditures of these insurance premiums. Effect: The Agency reported expenditures of $210,729 for insurance in reporting period 2, for which a portion would have been expensed under accrual accounting after the period of availability, resulting in a reportable finding. Based on accrual accounting, the Agency could have reported $275,042 of insurance expense during the period of availability from January 1, 2020 to December 31, 2021. This is based on the prior year?s policy that would have been amortized during the period of availability under accrual accounting. This resulted in insurance expense of $64,313 not claimed as an allowable cost. Recommendation: Management should implement procedures to ensure grant funds are expended as needed for allowable costs during the applicable periods of availability based on accrual accounting. View of Responsible Officials: Management will review all invoices to determine allowability under the specific grant?s rules and regulations and ensure grant funds are expended during the period of availability. Management felt that the insurance expenditures for the policy period July 1, 2020 to June 30, 2021, which were expensed during the period of availability, were comparable to those of the new policy year, which were paid, therefore the payment of the 2022 insurance was claimed on the reporting rather than completing an analysis of GAAP expenses.
Finding 2022-004 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Internal Control, Significant Deficiency Compliance Requirement: Allowable Costs Questioned Cost: $0 Condition: In Provider Relief Fund reporting period 2, Moore Center Services, Inc., reported expenditures for personnel payroll related costs for COVID-19 Crisis Management positions. The payroll submitted in the portal for expenditure, did not agree to the payroll records for the two employees in this position and managements allocation of their time devoted to COVID-19 related issues. Management had a calculation error for the eligible payroll of these two employees that was not identified during management?s review of the expenditures allocated to the Provider Relief Funds. Based on the payroll records and the correct allocation of payroll to COVID-19 expense, expenditures reported in period 2 were over reported by $13,003. However, the Agency has additional COVID-19 expenditures that can be allocated to the period 2 reporting. Criteria: The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. Cause: The Provider Relief Fund Post-Payment Notice of Reporting Requirements states that workforce-related costs paid to prevent, prepare for, or respond to coronavirus are eligible expenditures. However, the amount claimed in reporting period 2, was not in agreement with payroll records and managements allocation of payroll to COVID-19. Effect: Expenditures for personnel costs were claimed in reporting period 2, that were not in agreement with documentation of COVID related costs, resulting in a reportable finding. Recommendation: Management should implement procedures to ensure grant funds are expended as needed for allowable costs during the applicable periods of availability and calculations of costs are reviewed by an appropriate level of management. View of Responsible Officials: Management will review personnel expenditures attributable to COVID and ensure that the correct expenditures are applied to the grant funding.
Finding 2022-002 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Allowable Costs Questioned Cost: $406,035 (Known Questioned Cost) Condition: In Provider Relief Fund reporting period 2, the Moore Center Services, Inc. reported expenditures of $406,035 related to an HVAC capital project that was not yet complete and placed into service by the end of the period of availability, of December 31, 2021. Criteria: The Provider Relief Fund Frequently Asked Questions (FAQs) state ?For projects that are a bundle of services and purchases of tangible items that cannot be separated, such as capital projects, construction projects, or alteration and renovation projects, the project costs cannot be reimbursed using Provider Relief Fund payments unless the project was fully completed by the end of the Period of Availability associated with the Payment Received Period.? This language was added to the FAQs, on August 30, 2021. Section III ? Federal Award Findings (Continued) Cause: The Provider Relief Fund Post-Payment Notice of Reporting Requirements state that updates to HVAC systems are an allowable use of the funds. The Agency began discussions of the HVAC project in Spring 2021, and entered into an agreement with a contractor during October 2021 and work on the project commenced in April 2022, but the project was not fully completed by the end of the Period of Availability (December 31, 2021) as required by the Provider Relief Fund FAQs. Effect: Expenditures for a capital project that was not complete by the end of the Period of Availability, were claimed in reporting period 2, which has resulted in a reportable finding. Recommendation: Management should implement procedures to ensure grant funds are expended on allowable costs during the applicable periods of availability. View of Responsible Officials: The Agency began discussions of the need for on HVAC update in the Spring of 2021. After receiving various proposals, the Agency entered into an agreement in October 2021 for an HVAC update. According to the Post-Payment Notice of Reporting Requirements HVAC updates are considered to be an allowable cost. The Agency relied on FAQ dated July 15, 2021, during their planning of the capital expenditure, which did not include a requirement that the capital project be fully complete by the end of the Period of Availability to be allowable. This requirement was added on August 30, 2021. The FAQ the Agency referred to, stated ?For purchases of tangible items made using Provider Relief Funds payments, the purchase does not need to be in the Reporting Entity?s possession (i.e. backordered personal protective equipment, capital equipment) to be considered an eligible expense.? HVAC projects at facilities require a significant amount of time to plan, design, and build under normal circumstances, even before taking into consideration complications added by the pandemic, which included contractor shortages, labor availability issues, and supply chain issues. The Agency in good faith, started the process of receiving bids for the project, entered into the contract, and committed funds to the project, using the guidance available at the time of the commitment. The project was part of the Agency?s initiative to prevent, prepare for, and respond to coronavirus and, accordingly, the Provider Relief Fund grants were used to help fund the initiative.
Finding 2022-003 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Internal Control, Significant Deficiency Compliance Requirement: Allowable Costs Questioned Cost: $0 Condition: In Provider Relief Fund reporting period 2, Moore Center Services, Inc., reported expenditures of $210,729 for insurance policy premium payments for the policy period of July 1, 2021 to June 30, 2022. Under GAAP accrual accounting, the insurance policy premiums would be amortized over the policy period of July 1, 2021 to June 30, 2022, resulting in 6 months of ineligible expense outside the period of availability ending December 31, 2021. Criteria: The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. The Provider Relief Fund Frequently Asked Questions (FAQs) state: ?Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.? Cause: The Provider Relief Fund Post-Payment Notice of Reporting Requirements states that premiums paid for property, malpractice, business insurance, or other insurance relevant to operations are an allowable expense. Therefore, the Agency applied the insurance premiums paid prior to the end of the period of availability of December 31, 2021 to the funding. However, the Agency, did not take into account the accrual basis of accounting for the expenditures of these insurance premiums. Effect: The Agency reported expenditures of $210,729 for insurance in reporting period 2, for which a portion would have been expensed under accrual accounting after the period of availability, resulting in a reportable finding. Based on accrual accounting, the Agency could have reported $275,042 of insurance expense during the period of availability from January 1, 2020 to December 31, 2021. This is based on the prior year?s policy that would have been amortized during the period of availability under accrual accounting. This resulted in insurance expense of $64,313 not claimed as an allowable cost. Recommendation: Management should implement procedures to ensure grant funds are expended as needed for allowable costs during the applicable periods of availability based on accrual accounting. View of Responsible Officials: Management will review all invoices to determine allowability under the specific grant?s rules and regulations and ensure grant funds are expended during the period of availability. Management felt that the insurance expenditures for the policy period July 1, 2020 to June 30, 2021, which were expensed during the period of availability, were comparable to those of the new policy year, which were paid, therefore the payment of the 2022 insurance was claimed on the reporting rather than completing an analysis of GAAP expenses.
Finding 2022-004 Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Internal Control, Significant Deficiency Compliance Requirement: Allowable Costs Questioned Cost: $0 Condition: In Provider Relief Fund reporting period 2, Moore Center Services, Inc., reported expenditures for personnel payroll related costs for COVID-19 Crisis Management positions. The payroll submitted in the portal for expenditure, did not agree to the payroll records for the two employees in this position and managements allocation of their time devoted to COVID-19 related issues. Management had a calculation error for the eligible payroll of these two employees that was not identified during management?s review of the expenditures allocated to the Provider Relief Funds. Based on the payroll records and the correct allocation of payroll to COVID-19 expense, expenditures reported in period 2 were over reported by $13,003. However, the Agency has additional COVID-19 expenditures that can be allocated to the period 2 reporting. Criteria: The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus and that the funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. Cause: The Provider Relief Fund Post-Payment Notice of Reporting Requirements states that workforce-related costs paid to prevent, prepare for, or respond to coronavirus are eligible expenditures. However, the amount claimed in reporting period 2, was not in agreement with payroll records and managements allocation of payroll to COVID-19. Effect: Expenditures for personnel costs were claimed in reporting period 2, that were not in agreement with documentation of COVID related costs, resulting in a reportable finding. Recommendation: Management should implement procedures to ensure grant funds are expended as needed for allowable costs during the applicable periods of availability and calculations of costs are reviewed by an appropriate level of management. View of Responsible Officials: Management will review personnel expenditures attributable to COVID and ensure that the correct expenditures are applied to the grant funding.