Finding 2022-002: Internal control deficiency and noncompliance over amounts reported in the Schedule of Expenditures of Federal Awards (SEFA). 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 ? Period 2: January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls, states: 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). In addition, the Office of Management and Budget Compliance Supplement states: ?SEFA reporting amounts for this program (including both expenditures and lost revenues) are based upon the PRF report that is required to be submitted to the HRSA reporting portal. For a FYE of June 30, 2022, and through FYEs of December 30, 2022, recipients should report in the SEFA, the expenditures and lost revenues for the Period 2 (payments received from July 1, 2020 to December 31, 2020) PRF report.? Condition: During our testing over the SEFA, we observed management did not have effective internal controls in place to ensure accurate reporting of the payments received in the SEFA. This resulted in an understatement of the amount reported in the SEFA. Cause: Management did not have effective internal controls in place to ensure accurate reporting of the payments received in the SEFA. Effect or potential effect: The payments received were incorrectly reported in the SEFA. Questioned costs: None. Context: During our testing over the SEFA, we obtained the PRF reports submitted to the HRSA PRF Reporting Portal and reconciled the total payments received to the SEFA. We observed the payments received totaled $80,708,470, which represents the expenditures and lost revenues for the Period 2 (payments received from July 1, 2020 to December 31, 2020), as compared to the initial amount reported in the SEFA of $48,692,755. This resulted in an understatement of the amount reported in the SEFA of $32,015,715. Management?s internal control over the review of the SEFA did not identify this understatement. The amount reported in the SEFA was subsequently corrected and the corrected amount is reflected in the data collection form. Identification as a repeat finding, if applicable: No. Recommendation: Management should develop and implement internal controls to ensure the completeness and accuracy of the SEFA, including a review of applicable guidance in preparing the SEFA. Views of responsible officials: Ochsner LSU Health will implement additional review and coordinated efforts across departments throughout the organization to ensure the SEFA contains accurate information in reporting of expenditures. Additionally, current applicable guidance will be reviewed again before finalization.
Finding 2022-003: Internal control deficiency and noncompliance over reporting of expenses attributable to coronavirus in the HRSA PRF Reporting Portal. 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 ? Period 2: January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls, states: 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 certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. ? The recipient shall submit reports as the secretary determines are needed to ensure compliance with conditions that are imposed on this payment, and such reports shall be in such form, with such content, as specified by the secretary in future program instructions directed to all recipients. The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states the following: ? Duplication of expenses and lost revenues is not permitted. ? Expenses and lost revenues may not be duplicated: payments may not be applied to the same expenses and lost revenues that were reported on in prior reporting periods. Condition: During our testing over reporting, we observed management did not have effective internal controls in place to ensure expenses reported in the HRSA PRF Reporting Portal were not duplicated. This resulted in an overstatement of expenses reported in the HRSA PRF Reporting Portal. Cause: Management did not have effective internal controls in place to ensure the reported expenses attributable to coronavirus reported in the HRSA PRF Reporting Portal were not duplicated. Effect or potential effect: The expenses attributable to coronavirus were reported incorrectly in the HRSA PRF Reporting Portal. Questioned costs: $13,942,445 ? Assistance Listing Number 93.498 The questioned costs were computed as the difference between the expenses attributable to coronavirus reported in the HRSA PRF Reporting Portal of $78,376,882 and the actual expenses attributable to coronavirus of $64,434,437. Context: During our testing over reporting, we obtained a listing of 2 PRF reports submitted to the HRSA PRF Reporting Portal and selected both reports for testing. We observed the expenses attributable to coronavirus reported in the Period 2 reports included expenses that were previously reported in the Period 1 reports (i.e., payments were applied to the same expenses that were reported on in prior reporting periods). The total overstatement of expenses calculated to be $13,942,445. Total expenses attributable to coronavirus submitted in the HRSA PRF Reporting Portal was $78,376,882 compared to actual expenses attributable to coronavirus of $64,434,437. Management?s control regarding the review of the PRF reports did not identify this overstatement when submitting the Period 2 report into the HRSA PRF Reporting Portal. The overstatement did not result in the entity having excess expenses and 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 HRSA PRF Reporting Portal. This will ensure the expenses reported in the HRSA PRF Reporting Portal are not duplicated. Views of responsible officials: Since the start of the Covid-19 pandemic, Ochsner LSU Health has coordinated efforts across multiple divisions throughout the organization to ensure compliance with the Provider Relief Fund that included leveraging publicly available information, outside consultants, and an internal review prior to management sign off. An additional level of review will be implemented whereby Ochsner?s Internal Audit Department will preview the preliminary HRSA PRF Report from the PRF Reporting Portal prior to submission to ensure expenses are not duplicated. In addition, Ochsner LSU Health will work with HRSA to understand the most appropriate manner to correct this issue within the Provider Relief Fund Portal.
Finding 2022-004: 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 ? Period 2: January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls, states: 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 certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. ? The recipient shall submit reports as the secretary determines are needed to ensure compliance with conditions that are imposed on this payment, and such reports shall be in such form, with such content, as specified by the secretary in future program instructions directed to all recipients. Condition: During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the HRSA PRF Reporting Portal were calculated correctly. This resulted in an understatement of lost revenues reported in the HRSA PRF Reporting Portal. Cause: Management did not have effective internal controls in place to ensure the reported lost revenues attributable to coronavirus reported in the HRSA PRF Reporting Portal were free from error. Effect or potential effect: The calculation of lost revenues attributable to coronavirus was reported incorrectly in the HRSA PRF Reporting Portal. Questioned costs: None. Context: During our testing over reporting, we obtained a listing of 2 PRF reports submitted to the HRSA PRF Reporting Portal and selected both reports for testing. We observed the calculation of lost revenues attributable to coronavirus utilized by management to report lost revenues in the HRSA PRF Reporting Portal did not have supporting documentation. Management prepared an updated calculation using the same methodology which resulted in total lost revenues of $18,706,671 compared to total lost revenues reported in the HRSA PRF Reporting Portal of $14,683,441 resulting in an increase of lost revenues of $4,023,230. Management?s control regarding the review of the PRF reports did not identify this understatement when submitting the Period 2 report into the HRSA PRF Reporting Portal. The understatement did not result in the entity having excess expenses and 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 HRSA PRF Reporting Portal. This will ensure the lost revenues reported in the HRSA PRF Reporting Portal is reported correctly. Views of responsible officials: Since the start of the Covid-19 pandemic, Ochsner LSU Health has coordinated efforts across multiple divisions throughout the organization to ensure compliance with the Provider Relief Fund that included leveraging publicly available information, outside consultants, and an internal review prior to management sign off. Ochsner LSU Health will ensure that all calculations are documented with detail supporting information. An additional quality control measure will be implemented whereby Ochsner?s Internal Audit Department will perform a detailed review of the calculation including tracing all formulas to ensure accuracy prior to management sign-off. In addition, Ochsner LSU Health will work with HRSA to understand the most appropriate manner to correct this issue within the Provider Relief Fund in the subsequent portal submissions.
Finding 2022-002: Internal control deficiency and noncompliance over amounts reported in the Schedule of Expenditures of Federal Awards (SEFA). 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 ? Period 2: January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls, states: 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). In addition, the Office of Management and Budget Compliance Supplement states: ?SEFA reporting amounts for this program (including both expenditures and lost revenues) are based upon the PRF report that is required to be submitted to the HRSA reporting portal. For a FYE of June 30, 2022, and through FYEs of December 30, 2022, recipients should report in the SEFA, the expenditures and lost revenues for the Period 2 (payments received from July 1, 2020 to December 31, 2020) PRF report.? Condition: During our testing over the SEFA, we observed management did not have effective internal controls in place to ensure accurate reporting of the payments received in the SEFA. This resulted in an understatement of the amount reported in the SEFA. Cause: Management did not have effective internal controls in place to ensure accurate reporting of the payments received in the SEFA. Effect or potential effect: The payments received were incorrectly reported in the SEFA. Questioned costs: None. Context: During our testing over the SEFA, we obtained the PRF reports submitted to the HRSA PRF Reporting Portal and reconciled the total payments received to the SEFA. We observed the payments received totaled $80,708,470, which represents the expenditures and lost revenues for the Period 2 (payments received from July 1, 2020 to December 31, 2020), as compared to the initial amount reported in the SEFA of $48,692,755. This resulted in an understatement of the amount reported in the SEFA of $32,015,715. Management?s internal control over the review of the SEFA did not identify this understatement. The amount reported in the SEFA was subsequently corrected and the corrected amount is reflected in the data collection form. Identification as a repeat finding, if applicable: No. Recommendation: Management should develop and implement internal controls to ensure the completeness and accuracy of the SEFA, including a review of applicable guidance in preparing the SEFA. Views of responsible officials: Ochsner LSU Health will implement additional review and coordinated efforts across departments throughout the organization to ensure the SEFA contains accurate information in reporting of expenditures. Additionally, current applicable guidance will be reviewed again before finalization.
Finding 2022-003: Internal control deficiency and noncompliance over reporting of expenses attributable to coronavirus in the HRSA PRF Reporting Portal. 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 ? Period 2: January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls, states: 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 certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. ? The recipient shall submit reports as the secretary determines are needed to ensure compliance with conditions that are imposed on this payment, and such reports shall be in such form, with such content, as specified by the secretary in future program instructions directed to all recipients. The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states the following: ? Duplication of expenses and lost revenues is not permitted. ? Expenses and lost revenues may not be duplicated: payments may not be applied to the same expenses and lost revenues that were reported on in prior reporting periods. Condition: During our testing over reporting, we observed management did not have effective internal controls in place to ensure expenses reported in the HRSA PRF Reporting Portal were not duplicated. This resulted in an overstatement of expenses reported in the HRSA PRF Reporting Portal. Cause: Management did not have effective internal controls in place to ensure the reported expenses attributable to coronavirus reported in the HRSA PRF Reporting Portal were not duplicated. Effect or potential effect: The expenses attributable to coronavirus were reported incorrectly in the HRSA PRF Reporting Portal. Questioned costs: $13,942,445 ? Assistance Listing Number 93.498 The questioned costs were computed as the difference between the expenses attributable to coronavirus reported in the HRSA PRF Reporting Portal of $78,376,882 and the actual expenses attributable to coronavirus of $64,434,437. Context: During our testing over reporting, we obtained a listing of 2 PRF reports submitted to the HRSA PRF Reporting Portal and selected both reports for testing. We observed the expenses attributable to coronavirus reported in the Period 2 reports included expenses that were previously reported in the Period 1 reports (i.e., payments were applied to the same expenses that were reported on in prior reporting periods). The total overstatement of expenses calculated to be $13,942,445. Total expenses attributable to coronavirus submitted in the HRSA PRF Reporting Portal was $78,376,882 compared to actual expenses attributable to coronavirus of $64,434,437. Management?s control regarding the review of the PRF reports did not identify this overstatement when submitting the Period 2 report into the HRSA PRF Reporting Portal. The overstatement did not result in the entity having excess expenses and 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 HRSA PRF Reporting Portal. This will ensure the expenses reported in the HRSA PRF Reporting Portal are not duplicated. Views of responsible officials: Since the start of the Covid-19 pandemic, Ochsner LSU Health has coordinated efforts across multiple divisions throughout the organization to ensure compliance with the Provider Relief Fund that included leveraging publicly available information, outside consultants, and an internal review prior to management sign off. An additional level of review will be implemented whereby Ochsner?s Internal Audit Department will preview the preliminary HRSA PRF Report from the PRF Reporting Portal prior to submission to ensure expenses are not duplicated. In addition, Ochsner LSU Health will work with HRSA to understand the most appropriate manner to correct this issue within the Provider Relief Fund Portal.
Finding 2022-004: 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 ? Period 2: January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls, states: 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 certifies that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. ? The recipient shall submit reports as the secretary determines are needed to ensure compliance with conditions that are imposed on this payment, and such reports shall be in such form, with such content, as specified by the secretary in future program instructions directed to all recipients. Condition: During our testing over reporting, we observed management did not have effective internal controls in place to ensure lost revenues reported in the HRSA PRF Reporting Portal were calculated correctly. This resulted in an understatement of lost revenues reported in the HRSA PRF Reporting Portal. Cause: Management did not have effective internal controls in place to ensure the reported lost revenues attributable to coronavirus reported in the HRSA PRF Reporting Portal were free from error. Effect or potential effect: The calculation of lost revenues attributable to coronavirus was reported incorrectly in the HRSA PRF Reporting Portal. Questioned costs: None. Context: During our testing over reporting, we obtained a listing of 2 PRF reports submitted to the HRSA PRF Reporting Portal and selected both reports for testing. We observed the calculation of lost revenues attributable to coronavirus utilized by management to report lost revenues in the HRSA PRF Reporting Portal did not have supporting documentation. Management prepared an updated calculation using the same methodology which resulted in total lost revenues of $18,706,671 compared to total lost revenues reported in the HRSA PRF Reporting Portal of $14,683,441 resulting in an increase of lost revenues of $4,023,230. Management?s control regarding the review of the PRF reports did not identify this understatement when submitting the Period 2 report into the HRSA PRF Reporting Portal. The understatement did not result in the entity having excess expenses and 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 HRSA PRF Reporting Portal. This will ensure the lost revenues reported in the HRSA PRF Reporting Portal is reported correctly. Views of responsible officials: Since the start of the Covid-19 pandemic, Ochsner LSU Health has coordinated efforts across multiple divisions throughout the organization to ensure compliance with the Provider Relief Fund that included leveraging publicly available information, outside consultants, and an internal review prior to management sign off. Ochsner LSU Health will ensure that all calculations are documented with detail supporting information. An additional quality control measure will be implemented whereby Ochsner?s Internal Audit Department will perform a detailed review of the calculation including tracing all formulas to ensure accuracy prior to management sign-off. In addition, Ochsner LSU Health will work with HRSA to understand the most appropriate manner to correct this issue within the Provider Relief Fund in the subsequent portal submissions.