Audit 54355

Finding 2022-001 Activities Allowed or Unallowed and Eligibility, Information on the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 Testing for the Uninsured Pass-Through Award Period of Performance: 01/01/2022-03/31/2022; Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?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).? Condition: The Company did not retain audit evidence to support the report logic that was developed to extract patients from the patient billing systems that were identified as having an allowable COVID-19 testing and treatment diagnosis code with uninsured eligibility determination and eligible for reimbursement under this federal program. In addition, supporting documentation was not retained to validate who had access to modify and run the script, what changes were made to the script and how any changes to the script were tested and implemented during the fiscal year based on changes to HRSA guidance and how management validated the completeness and accuracy of the data extracted by the script. Cause: The Revenue Cycle department did not develop and maintain effective internal control over report writing, program changes and user access. In addition, while management represented that the report logic and subsequent changes to the report logic were reviewed, no audit evidence was retained to support that process. Questioned costs: None. Context: Total federal expenditures for Assistance Listing 93.461 totaled $1,214,572 for the year ended December 31, 2022. Effect or potential effect: The key report used to identify eligible federal program participants could be inaccurate or incomplete. Identification as a repeat finding, if applicable: The finding is a repeat of finding 2021-004 from the prior year. Recommendation: Although the program has now ended, the Company should retain evidence of internal controls related to access and change management over the report should the program be reinstated. Additionally, management should implement a quality review process of eligible claims identified on a monthly basis to ensure that patients identified meet the required eligibility requirements. Views of Responsible Officials: As part of the prior year audit finding, the Company implemented a process as of January 2022 to document internal controls related to the quality review of claims to ensure patients meet the eligibility requirements. HRSA reviewed the documentation and determined that the finding had been satisfactorily resolved. Although the program has now ended, the Company will ensure the internal controls are documented should the HRSA program be reinstated.

Finding 2022-001 Activities Allowed or Unallowed and Eligibility, Information on the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 Testing for the Uninsured Pass-Through Award Period of Performance: 01/01/2022-03/31/2022; Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?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).? Condition: The Company did not retain audit evidence to support the report logic that was developed to extract patients from the patient billing systems that were identified as having an allowable COVID-19 testing and treatment diagnosis code with uninsured eligibility determination and eligible for reimbursement under this federal program. In addition, supporting documentation was not retained to validate who had access to modify and run the script, what changes were made to the script and how any changes to the script were tested and implemented during the fiscal year based on changes to HRSA guidance and how management validated the completeness and accuracy of the data extracted by the script. Cause: The Revenue Cycle department did not develop and maintain effective internal control over report writing, program changes and user access. In addition, while management represented that the report logic and subsequent changes to the report logic were reviewed, no audit evidence was retained to support that process. Questioned costs: None. Context: Total federal expenditures for Assistance Listing 93.461 totaled $1,214,572 for the year ended December 31, 2022. Effect or potential effect: The key report used to identify eligible federal program participants could be inaccurate or incomplete. Identification as a repeat finding, if applicable: The finding is a repeat of finding 2021-004 from the prior year. Recommendation: Although the program has now ended, the Company should retain evidence of internal controls related to access and change management over the report should the program be reinstated. Additionally, management should implement a quality review process of eligible claims identified on a monthly basis to ensure that patients identified meet the required eligibility requirements. Views of Responsible Officials: As part of the prior year audit finding, the Company implemented a process as of January 2022 to document internal controls related to the quality review of claims to ensure patients meet the eligibility requirements. HRSA reviewed the documentation and determined that the finding had been satisfactorily resolved. Although the program has now ended, the Company will ensure the internal controls are documented should the HRSA program be reinstated.