FAC Explorer

Audit 55778

FY End
2022-09-30
Total Expended
$57.50M
Findings
4
Programs
29
Organization: The University of Vermont Health Network INC (VT)
Year: 2022 Accepted: 2023-06-29
Auditor: Ernst & Young LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
59688 2022-002 Material Weakness - P
59689 2022-001 Significant Deficiency - AB
636130 2022-002 Material Weakness - P
636131 2022-001 Significant Deficiency - AB

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $50.71M Yes 1
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $512,018 - 0
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $501,123 - 0
93.461 Covid-19 Testing for the Uninsured $323,290 Yes 1
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $294,892 - 0
93.155 Rural Health Research Centers $256,051 - 0
93.940 Hiv Prevention Activities_health Department Based $139,746 - 0
93.251 Early Hearing Detection and Intervention $98,965 - 0
93.917 Hiv Care Formula Grants $89,675 - 0
84.268 Federal Direct Student Loans $76,840 - 0
93.253 Poison Center Support and Enhancement Grant $55,077 - 0
93.778 Medical Assistance Program $53,965 - 0
93.314 Early Hearing Detection and Intervention Information System (ehdi-Is) Surveillance Program $52,129 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $51,954 - 0
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $41,895 - 0
93.575 Child Care and Development Block Grant $41,125 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $41,023 - 0
93.889 National Bioterrorism Hospital Preparedness Program $40,000 - 0
84.181 Special Education-Grants for Infants and Families $37,199 - 0
93.145 Aids Education and Training Centers $36,879 - 0
84.063 Federal Pell Grant Program $23,353 - 0
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $20,186 - 0
10.558 Child and Adult Care Food Program $16,616 - 0
93.110 Maternal and Child Health Federal Consolidated Programs $13,566 - 0
93.301 Small Rural Hospital Improvement Grant Program $12,836 - 0
93.070 Environmental Public Health and Emergency Response $6,283 - 0
93.865 Child Health and Human Development Extramural Research $4,106 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $3,036 - 0
93.994 Maternal and Child Health Services Block Grant to the States $681 - 0

Contacts

Name Title Type
CEX7F74WQ8B5 Rick Vincent Auditee
8028472089 Jessica Liconti Auditor
No contacts on file

Notes to SEFA

Title: COVID-19 Provider Relief Fund Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) presents the federal grant expenditures of The University of Vermont Health Network Inc. and its subsidiaries (the Network) for the year ended September 30, 2022. Federal program expenditures included in the accompanying Schedule are presented on the accrual basis of accounting. The information in this 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 (Uniform Guidance). In accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Note 2). Therefore, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the Networks consolidated financial statements. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loan and loan guarantees, or other non-cash assistance. Negative amounts represent adjustments or credits to amounts reported as expenditures in prior years.Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX for awards subject to the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Network has elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The Schedule includes grant activity related to the Department of Health and Human Services (HHS) COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Distribution Assistance Listing Number 93.498. As required based on guidance in the 2022 OMB Compliance Supplement, the Schedule includes all Period 2 and Period 3 funds received between July 1, 2020 and June 30, 2021 and expended by June 30, 2022, as reported to the Health Resources and Services Administration (HRSA) via the PRF Reporting Portal.The amounts reported in the Schedule reconcile to the PRF information previously reported to the HRSA for PRF Reporting Periods 2 and 3 as follows:Reporting Period 2: Activity from the period January 1, 2020 through December 31, 2021Name of Reporting Entity for HRSA Reporting Period 2 Provider Relief Fund ReportReporting Entity Tax Identification Number (TIN)Type ofDistributionTotal Other PRF Payments Applied to Unreimbursed Expenses Attributable to COVID-19Total Other PRF Payments Applied to Lost RevenuesTotal Amount Reported on the Accompanying Schedule for the Year Ended September 30, 2022 Alice Hyde Medical Center150346515General/Targeted$$5,103,253$5,103,253Infection Control215,040215,040Central Vermont Medical Center, Inc.222547186General/Targeted635,323635,323Infection Control251,317251,317Champlain Valley Physicians Hospital141338471, 061718419General/Targeted254,952254,952141338471Infection Control153,687153,687Helen Porter Nursing Home30306549Infection Control163,895163,895Porter Medical Center, Inc.30181058General/Targeted93,80793,807University of Vermont Medical Center, Inc.30219309,43691034General/Targeted7,957,8737,957,873$783,939$14,045,208$14,829,147Reporting Period 3: Activity from the period January 1, 2020 through June 30, 2022Name of Reporting Entity for HRSA Reporting Period 3 Provider Relief Fund ReportReporting Entity Tax Identification Number (TIN)Type ofDistributionTotal Other PRF Payments Applied to Unreimbursed Expenses Attributable to COVID-19Total Other PRF Payments Applied to Lost RevenuesTotal Amount Reported on the Accompanying Schedule for the Year Ended September 30, 2022 Central Vermont Medical Center, Inc.222547186Infection Control$169,392$$169,392Champlain Valley Physicians Hospital141338471Infection Control34,01134,011Helen Porter Nursing Home30306549Infection Control32,08432,084University of Vermont Medical Center, Inc.30219309,43691034General/Targeted9,889,19125,758,93635,648,127$10,124,678$25,758,936$35,883,614The expenses attributable to Coronavirus Disease 2019 (COVID-19) and lost revenues incurred by the Network during the period of availability for PRF Reporting Periods 2 and 3 are in excess of the general, targeted and infection control distributions received in PRF Reporting Period 1 (which addressed payments received during April 10, 2020 to June 30, 2020, and previously reported on the Schedule of Expenditures of Federal Awards for the year ended September 30, 2021) and distributions received from July 1, 2020 through June 30, 2021 and, therefore, the amounts presented in the table above and on the accompanying Schedule are limited to the amount of such distributions. The Network received additional PRF payments subsequent to June 30, 2021, which are required to be reported in subsequent HRSA PRF Reporting Periods and, accordingly, pursuant to the requirements specific to Assistance Listing No. 93.498, such amounts are excluded from the accompanying Schedule.
Title: COVID-19 HRSA COVID-19 Claims Reimbursement for the Uninsured Program Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the Schedule) presents the federal grant expenditures of The University of Vermont Health Network Inc. and its subsidiaries (the Network) for the year ended September 30, 2022. Federal program expenditures included in the accompanying Schedule are presented on the accrual basis of accounting. The information in this 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 (Uniform Guidance). In accordance with applicable requirements, certain programs may be presented in a fiscal period based on the program-specific guidance (see Note 2). Therefore, some amounts presented in the Schedule may differ from amounts presented in or used in the preparation of the Networks consolidated financial statements. For purposes of the Schedule, federal awards include any assistance provided by a federal agency directly or indirectly in the form of grants, contracts, cooperative agreements, loan and loan guarantees, or other non-cash assistance. Negative amounts represent adjustments or credits to amounts reported as expenditures in prior years.Direct and indirect costs are charged to awards in accordance with cost principles contained in the United States Department of Health and Human Services Cost Principles for Hospitals at 45 CFR Part 75 Appendix IX for awards subject to the Uniform Guidance. Under these cost principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Network has elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. In the year ended September 30, 2022, the Network commenced a review of services rendered under Assistance Listing Number 93.461 to ensure claims for reimbursement to HRSA were submitted for services rendered to uninsured patients related to COVID-19. As a result of this review, refunds have been remitted to HRSA. The amount reported on the Schedule is net of the actual and estimated refunds to HRSA related to 2022 dates of service of approximately $0.2 million. Management believes that the amounts reported on the Schedule, based on these estimates, are reasonable and any differences between estimates and actual should not have a material effect on the Schedule.

Finding Details

Finding 2022-002
Finding 2022-002 ? Material weakness over amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) Identification of the federal program: Assistance Listing Number 93.461: ? COVID-19 ? HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund ? U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) ? Federal award identification number ? Various ? Federal award year ?October 1, 2021 through September 30, 2022 Criteria or specific requirement: 2 CFR 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 preliminary SEFA expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured program incorrectly included claims reimbursements which were later refunded to HRSA, did not appropriately cut off transactions based on date of service for the year ended September 30, 2022, and incorrectly excluded HRSA COVID-19 claims reimbursements received by Champlain Valley Physicians Hospital. Cause: Management did not have effective internal controls in place to ensure accurate reporting of the payments received for the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Effect or potential effect: The payments were incorrected reported in the preliminary SEFA for the year ended September 30, 2022. Questioned costs: None. Context: A preliminary version of the SEFA prepared by management included expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured program of $524,543. After commencement of the Uniform Guidance audit procedures and resolution of the issues noted above, adjustments of ($201,253) were made to correct the SEFA expenditures to $323,290. Identification as a repeat finding, if applicable: No. Recommendation: Management should reassess its internal controls over reporting of the payments received for the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Views of responsible individuals: Management agrees with finding as noted above. Management notes that this program is complete, and expenditures will not be incurred nor included on the SEFA in future years. However, management acknowledges the need for complete and accurate reporting on the SEFA. The Network Grants Management Finance team is expanding to work toward centralization of grant tracking. Management has budgeted for an additional FTE within the GMF team in FY23 to engage in this work to centralize grant tracking, which will continue to enhance our controls to ensure completeness and accuracy of the consolidated Network Schedule of Expenditures of Federal Awards.
Finding 2022-001
Finding 2022-001 ? Significant deficiency in documentation supporting Provider Relief Fund expenditures 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 (HHS), Health Resources and Services Administration (HRSA) ? Federal award identification number ? Not Applicable ? Federal award year ? Period 3: January 1, 2020 to June 30, 2022 Criteria or specific requirement: 2 CFR 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: University of Vermont Medical Center, Inc. (UVMMC) submitted $9,889,191 in expenditures to the HRSA Provider Relief Fund (PRF) portal for reporting period 3. Management did not initially retain a listing of these expenditures at an appropriate sampling unit level until the Uniform Guidance audit commencement. Within this listing, certain expenditures for travelling nurses agreed to certified timecards and approved payrates, but management did not retain approval documentation of the reconciliation for these expenditures to vendor invoices. In addition, management did not retain adequate documentation of a change to its PRF reporting and expenditure submission strategy. Subsequent to submission of UVMMC?s HRSA reporting period 1 data, certain reported expenditures were obligated by an alternate federal funding source. For PRF purposes, management ?replaced? these newly unallowable expenditures with lost revenues for the applicable PRF period, in line with HRSA guidance (as described in HRSA?s frequently asked questions available on the HRSA website). HRSA guidance requires maintenance of appropriate documentation to support deductions of expenditures from prior reporting periods (as adjustments cannot be made retroactively within the HRSA portal). While this change in expenditure reimbursement approach was extensively discussed and approved by the appropriate level of UVMMC personnel, documentation of this change was not prepared or retained by management until audit commencement. Finally, management did not retain adequate approval documentation that expenditures for travelling nurses submitted to the HRSA PRF portal in reporting period 3 were not duplicated with expenditures reimbursed from other sources until audit commencement. Cause: Management represented that they performed a review and approval of PRF expenditures for allowability; however, supporting documentation to evidence that internal controls were sufficiently designed and operating effectively was not maintained. Effect or potential effect: A lack of internal controls over the review and approval of expenditures for allowability could result in unallowable expenses being charged to the PRF program. Questioned costs: None. Context: Total expenditures reported by UVMMC in the HRSA portal in reporting period 3 are $9,889,191. Total PRF lost revenue and expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) by UVMMC are $43,606,000 for the year ended September 30, 2022. Identification as a repeat finding, if applicable: No. Recommendation: Management should reassess its internal controls over the review and approval of allowability of PRF expenditures. Management should retain more robust documentation related to its review processes, including evidencing approval of the review of methodology and detail reports used to reconcile to amounts reported on the SEFA. Views of responsible individuals: Management agrees and has reassessed its internal controls over the review and approval of allowable expenditures under this program. Management has updated its documentation for this program reviewed under this audit and is in the process of updating other documentation related to HRSA reporting periods 4 and 5.
Finding 2022-002
Finding 2022-002 ? Material weakness over amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) Identification of the federal program: Assistance Listing Number 93.461: ? COVID-19 ? HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund ? U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) ? Federal award identification number ? Various ? Federal award year ?October 1, 2021 through September 30, 2022 Criteria or specific requirement: 2 CFR 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 preliminary SEFA expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured program incorrectly included claims reimbursements which were later refunded to HRSA, did not appropriately cut off transactions based on date of service for the year ended September 30, 2022, and incorrectly excluded HRSA COVID-19 claims reimbursements received by Champlain Valley Physicians Hospital. Cause: Management did not have effective internal controls in place to ensure accurate reporting of the payments received for the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Effect or potential effect: The payments were incorrected reported in the preliminary SEFA for the year ended September 30, 2022. Questioned costs: None. Context: A preliminary version of the SEFA prepared by management included expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured program of $524,543. After commencement of the Uniform Guidance audit procedures and resolution of the issues noted above, adjustments of ($201,253) were made to correct the SEFA expenditures to $323,290. Identification as a repeat finding, if applicable: No. Recommendation: Management should reassess its internal controls over reporting of the payments received for the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Views of responsible individuals: Management agrees with finding as noted above. Management notes that this program is complete, and expenditures will not be incurred nor included on the SEFA in future years. However, management acknowledges the need for complete and accurate reporting on the SEFA. The Network Grants Management Finance team is expanding to work toward centralization of grant tracking. Management has budgeted for an additional FTE within the GMF team in FY23 to engage in this work to centralize grant tracking, which will continue to enhance our controls to ensure completeness and accuracy of the consolidated Network Schedule of Expenditures of Federal Awards.
Finding 2022-001
Finding 2022-001 ? Significant deficiency in documentation supporting Provider Relief Fund expenditures 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 (HHS), Health Resources and Services Administration (HRSA) ? Federal award identification number ? Not Applicable ? Federal award year ? Period 3: January 1, 2020 to June 30, 2022 Criteria or specific requirement: 2 CFR 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: University of Vermont Medical Center, Inc. (UVMMC) submitted $9,889,191 in expenditures to the HRSA Provider Relief Fund (PRF) portal for reporting period 3. Management did not initially retain a listing of these expenditures at an appropriate sampling unit level until the Uniform Guidance audit commencement. Within this listing, certain expenditures for travelling nurses agreed to certified timecards and approved payrates, but management did not retain approval documentation of the reconciliation for these expenditures to vendor invoices. In addition, management did not retain adequate documentation of a change to its PRF reporting and expenditure submission strategy. Subsequent to submission of UVMMC?s HRSA reporting period 1 data, certain reported expenditures were obligated by an alternate federal funding source. For PRF purposes, management ?replaced? these newly unallowable expenditures with lost revenues for the applicable PRF period, in line with HRSA guidance (as described in HRSA?s frequently asked questions available on the HRSA website). HRSA guidance requires maintenance of appropriate documentation to support deductions of expenditures from prior reporting periods (as adjustments cannot be made retroactively within the HRSA portal). While this change in expenditure reimbursement approach was extensively discussed and approved by the appropriate level of UVMMC personnel, documentation of this change was not prepared or retained by management until audit commencement. Finally, management did not retain adequate approval documentation that expenditures for travelling nurses submitted to the HRSA PRF portal in reporting period 3 were not duplicated with expenditures reimbursed from other sources until audit commencement. Cause: Management represented that they performed a review and approval of PRF expenditures for allowability; however, supporting documentation to evidence that internal controls were sufficiently designed and operating effectively was not maintained. Effect or potential effect: A lack of internal controls over the review and approval of expenditures for allowability could result in unallowable expenses being charged to the PRF program. Questioned costs: None. Context: Total expenditures reported by UVMMC in the HRSA portal in reporting period 3 are $9,889,191. Total PRF lost revenue and expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) by UVMMC are $43,606,000 for the year ended September 30, 2022. Identification as a repeat finding, if applicable: No. Recommendation: Management should reassess its internal controls over the review and approval of allowability of PRF expenditures. Management should retain more robust documentation related to its review processes, including evidencing approval of the review of methodology and detail reports used to reconcile to amounts reported on the SEFA. Views of responsible individuals: Management agrees and has reassessed its internal controls over the review and approval of allowable expenditures under this program. Management has updated its documentation for this program reviewed under this audit and is in the process of updating other documentation related to HRSA reporting periods 4 and 5.