Audit 55905

FY End
2022-06-30
Total Expended
$13.14M
Findings
8
Programs
3
Organization: Lutheran Seniorlife (PA)
Year: 2022 Accepted: 2023-03-30

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
58426 2022-003 Significant Deficiency - P
58427 2022-004 Significant Deficiency - P
58428 2022-001 Significant Deficiency Yes L
58429 2022-002 Significant Deficiency - L
634868 2022-003 Significant Deficiency - P
634869 2022-004 Significant Deficiency - P
634870 2022-001 Significant Deficiency Yes L
634871 2022-002 Significant Deficiency - L

Contacts

Name Title Type
D6W1TU86W1H7 Jeffrey Carraway Auditee
7247422246 Ryan Santarella Auditor
No contacts on file

Notes to SEFA

Title: LOAN PROGRAMS Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes thefederal award activity of Lutheran SeniorLife and Affiliates under programs of the federalgovernment for the year ended June 30, 2022. The information in this Schedule is presentedin accordance with the requirements of 2 CFR Part 200, Uniform AdministrativeRequirements, Cost Principles, and Audit Requirements for Federal Awards (UniformGuidance). Because the Schedule presents only a selected portion of the operations ofLutheran SeniorLife and Affiliates, it is not intended to and does not present the financialposition, changes in net assets, or cash flows of Lutheran SeniorLife and Affiliates. Expenditures reported on the Schedule are reported on the accrual basis of accounting.Such expenditures are recognized following, as applicable, either the cost principles in OMBCircular A-122, Cost Principles for Non-Profit Organizations, or the cost principles containedin Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements,Cost Principles, and Audit Requirements for Federal Awards, wherein certain types ofexpenditures are not allowable or are limited as to reimbursement.The consolidated financial statements reflect revenue recognized from the Provider ReliefFund of $0 and $1,196,830 in the years ended June 30, 2022 and 2021, respectively. TheSchedule includes Provider Relief Funds of $1,196,830 that were received in Periods 2 and3 in accordance with the requirements of the compliance supplement for assistance listingnumber 93.498. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The U.S. Department of Housing and Urban Development insurance loan balance and theU.S. Department of Agriculture loan balance as of July 1, 2021 are included in the federalexpenditures in the schedule. Lutheran SeniorLife and Affiliates has no outstanding loanbalances as of June 30, 2022 with continuing compliance requirements.

Finding Details

2022-003 Federal agency: U.S. Department of Housing and Urban Development Federal program title: Mortgage Insurance ? Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities Assistance Living Number: 14.129 Award Period: Year Ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Failure to Maintain Approved Management Agreements Condition: St. John Lutheran Care Center (St. John) was charged a management fee by Lutheran SeniorLife, its parent but did not have an approved management contract meeting the requirements of the regulatory agreement. Questioned costs: $0. Context: St. John did not have an approved management agreement. Cause: St. John?s existing management agreement was with Lutheran Affiliated Services (LAS) from 1992 and had not been updated to reflect the current management fee charged by the successor to LAS, Lutheran SeniorLife. Effect: The management agreement was not approved by HUD and did not contain the provisions required by the regulatory agreement. Recommendation: St. John should enter into an approved management agreement with Lutheran SeniorLife.Views of Responsible Officials and Planned Corrective Actions: St. John updated internal agreements to reflect the change from Lutheran Affiliated Services to Lutheran SeniorLife, but neglected to complete the process with HUD. St John will submit the paperwork to obtain a certified HUD approved management agreement. While the organization was operating without this agreement in place, management fees charged were only to reimburse costs incurred in performing these management functions. During Fiscal Year 2021, St John entered into a refinancing plan with a lender in order to facilitate a repositioning of the facility and to enable facility improvements that were identified. The closing on the refinancing of the existing HUD loan took place on July 8, 2021.
2022-004 Federal agency: U.S. Department of Housing and Urban Development Federal program title: Mortgage Insurance ? Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities Assistance Listing Number: 14.129 Award Period: Year Ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Controls over Compliance ? Other Matters Criteria or specific requirement: REAC Inspection Results Condition: St. John received a REAC inspection score of less than 31, which denotes the property has physical deficiencies that do not meet contractual obligations to HUD. Questioned costs: None. Context: Results of REAC inspection 613308. Cause: St. John has not corrected all deficiencies identified during the REAC inspection. Effect: Noncompliance with HUD requirements. Recommendation: St. John should work to address all REAC inspection findings.Views of Responsible Officials and Planned Corrective Actions: Subsequent to this survey, the facility incurred significant flooding, which required immediate action. Due to this, St. John did not have the ability to address the findings from the survey. With a protracted insurance claims process and the impact of Covid-19 on building operations, work on the outstanding deficiencies has been delayed. Due to the risk to residents and staff, all outside visitors including maintenance contractors and other vendors has been limited for a number of periods during the pandemic during FY21. Management completed an assessment of the facility?s use and has begun a repositioning plan to bring new living options into the building. In order to complete the needed improvements to the building, St. John has completed a refinancing of its existing HUD debt and negotiated a construction loan to fund the improvements. The closing on the refinancing of the existing HUD loan and the construction loan took place on July 8, 2021.
2022-001 Federal agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19 Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Year ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Controls over Compliance ? Other Matters Criteria or specific requirement: 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. These funds may not be used to reimburse expenses of losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Condition: The Organization's internal controls over reporting were not effective. Questioned costs: $0 Context: During the audit, it was determined that on three out of five reports selected for testing, lost revenue was overstated due to differences between revenue reported under the actual revenue method (option one) for reporting lost revenue and the underlying internal financial information. Cause: The system generated report used to compile revenue information for the reports did not include all revenue activity. Effect: Reported lost revenue was calculated incorrectly. On two of the reports selected, there was sufficient lost revenue after accounting for this overreporting to utilize all of the Provider Relief Funds reported. On the other report selected, all Provider Relief Funds were allocated to expenditures.Recommendation: We recommend management implement additional procedures to review reported revenue before submitting reports and adjust the system report used to compile the revenue information to ensure it is correct and reflects the utilization of Provider Relief Funds to replace lost revenue. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the error in selecting an incomplete management revenue report for reporting purposes. For future reporting periods, management will correct the management report utilized and ensure it balances with total revenues. Management will correct the amounts report for 2019 through 2022 beginning with Provider Relief Funds reporting period #4.
2022-002 Federal agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19 Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Year ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Controls over Compliance ? Other Matters Criteria or specific requirement: 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. These funds may not be used to reimburse expenses of losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Condition: The Organization's internal controls over reporting were not effective. Questioned costs: $0 Context: During the audit, it was determined that one out of 13 expenditures selected for testing did not agree to the supporting payment. Cause: Purchase order information was used to accumulate COVID-19 related costs for reporting on during reporting period three. The amount paid for the items on the purchase order was less than the original purchase order.Effect: The listing of expenditures used to populate the report was overstated due to using purchase order information. There were sufficient other expenditures to utilize the infection control payment. Recommendation: We recommend expenditures only be allocated to Provider Relief Funds after they have been paid. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the error in the report and for future reporting periods will verify expenditures have been paid before reporting.
2022-003 Federal agency: U.S. Department of Housing and Urban Development Federal program title: Mortgage Insurance ? Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities Assistance Living Number: 14.129 Award Period: Year Ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Failure to Maintain Approved Management Agreements Condition: St. John Lutheran Care Center (St. John) was charged a management fee by Lutheran SeniorLife, its parent but did not have an approved management contract meeting the requirements of the regulatory agreement. Questioned costs: $0. Context: St. John did not have an approved management agreement. Cause: St. John?s existing management agreement was with Lutheran Affiliated Services (LAS) from 1992 and had not been updated to reflect the current management fee charged by the successor to LAS, Lutheran SeniorLife. Effect: The management agreement was not approved by HUD and did not contain the provisions required by the regulatory agreement. Recommendation: St. John should enter into an approved management agreement with Lutheran SeniorLife.Views of Responsible Officials and Planned Corrective Actions: St. John updated internal agreements to reflect the change from Lutheran Affiliated Services to Lutheran SeniorLife, but neglected to complete the process with HUD. St John will submit the paperwork to obtain a certified HUD approved management agreement. While the organization was operating without this agreement in place, management fees charged were only to reimburse costs incurred in performing these management functions. During Fiscal Year 2021, St John entered into a refinancing plan with a lender in order to facilitate a repositioning of the facility and to enable facility improvements that were identified. The closing on the refinancing of the existing HUD loan took place on July 8, 2021.
2022-004 Federal agency: U.S. Department of Housing and Urban Development Federal program title: Mortgage Insurance ? Nursing Homes, Intermediate Care Facilities, Board and Care Homes, and Assisted Living Facilities Assistance Listing Number: 14.129 Award Period: Year Ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Controls over Compliance ? Other Matters Criteria or specific requirement: REAC Inspection Results Condition: St. John received a REAC inspection score of less than 31, which denotes the property has physical deficiencies that do not meet contractual obligations to HUD. Questioned costs: None. Context: Results of REAC inspection 613308. Cause: St. John has not corrected all deficiencies identified during the REAC inspection. Effect: Noncompliance with HUD requirements. Recommendation: St. John should work to address all REAC inspection findings.Views of Responsible Officials and Planned Corrective Actions: Subsequent to this survey, the facility incurred significant flooding, which required immediate action. Due to this, St. John did not have the ability to address the findings from the survey. With a protracted insurance claims process and the impact of Covid-19 on building operations, work on the outstanding deficiencies has been delayed. Due to the risk to residents and staff, all outside visitors including maintenance contractors and other vendors has been limited for a number of periods during the pandemic during FY21. Management completed an assessment of the facility?s use and has begun a repositioning plan to bring new living options into the building. In order to complete the needed improvements to the building, St. John has completed a refinancing of its existing HUD debt and negotiated a construction loan to fund the improvements. The closing on the refinancing of the existing HUD loan and the construction loan took place on July 8, 2021.
2022-001 Federal agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19 Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Year ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Controls over Compliance ? Other Matters Criteria or specific requirement: 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. These funds may not be used to reimburse expenses of losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Condition: The Organization's internal controls over reporting were not effective. Questioned costs: $0 Context: During the audit, it was determined that on three out of five reports selected for testing, lost revenue was overstated due to differences between revenue reported under the actual revenue method (option one) for reporting lost revenue and the underlying internal financial information. Cause: The system generated report used to compile revenue information for the reports did not include all revenue activity. Effect: Reported lost revenue was calculated incorrectly. On two of the reports selected, there was sufficient lost revenue after accounting for this overreporting to utilize all of the Provider Relief Funds reported. On the other report selected, all Provider Relief Funds were allocated to expenditures.Recommendation: We recommend management implement additional procedures to review reported revenue before submitting reports and adjust the system report used to compile the revenue information to ensure it is correct and reflects the utilization of Provider Relief Funds to replace lost revenue. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the error in selecting an incomplete management revenue report for reporting purposes. For future reporting periods, management will correct the management report utilized and ensure it balances with total revenues. Management will correct the amounts report for 2019 through 2022 beginning with Provider Relief Funds reporting period #4.
2022-002 Federal agency: U.S. Department of Health and Human Services Federal Program Title: COVID-19 Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Year ended June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Controls over Compliance ? Other Matters Criteria or specific requirement: 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. These funds may not be used to reimburse expenses of losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Condition: The Organization's internal controls over reporting were not effective. Questioned costs: $0 Context: During the audit, it was determined that one out of 13 expenditures selected for testing did not agree to the supporting payment. Cause: Purchase order information was used to accumulate COVID-19 related costs for reporting on during reporting period three. The amount paid for the items on the purchase order was less than the original purchase order.Effect: The listing of expenditures used to populate the report was overstated due to using purchase order information. There were sufficient other expenditures to utilize the infection control payment. Recommendation: We recommend expenditures only be allocated to Provider Relief Funds after they have been paid. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the error in the report and for future reporting periods will verify expenditures have been paid before reporting.