Audit 9075

FY End
2023-03-31
Total Expended
$827,345
Findings
2
Programs
1
Year: 2023 Accepted: 2024-01-02

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
7067 2023-001 Significant Deficiency - ABL
583509 2023-001 Significant Deficiency - ABL

Programs

ALN Program Spent Major Findings
93.498 Provider Relief Fund $827,345 Yes 1

Contacts

Name Title Type
L6MNQF96PW94 Karalyn Bere Auditee
7814336676 Danielle Hawley Auditor
No contacts on file

Notes to SEFA

Title: General Accounting Policies: Basis of Presentation The accompanying Schedule of Other Revenues of HHS Award (the Schedule) is prepared in accordance with accounting principles generally accepted in the United States of America and the requirements of Title 45 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule includes revenue of the HHS Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution program of the Company for the periods of availability which ended in the year ended March 31, 2023. Because the Schedule presents only a selected portion of the Company's revenue, it is not intended to and does not present the financial position, changes in net deficit or cash flows of the Company. De Minimis Rate Used: N Rate Explanation: The Company has not elected to use the 10% de minimis indirect cost rate. North Hill Communities, Inc. (Communities) is a not-for-profit corporation located in Needham, Massachusetts organized to benefit, support and further the charitable activities of its affiliates, for which it is the sole corporate member. Communities, and its affiliates, (the Company) have been serving residents since 1984 on a 59-acre leased site. The life care retirement community includes 320 independent living units, 44 enhanced living units, a 72 bed skilled nursing facility, a home health agency and a lifecare at home program.
Title: Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution - Assistance Listing Number 93.498 Accounting Policies: Basis of Presentation The accompanying Schedule of Other Revenues of HHS Award (the Schedule) is prepared in accordance with accounting principles generally accepted in the United States of America and the requirements of Title 45 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule includes revenue of the HHS Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution program of the Company for the periods of availability which ended in the year ended March 31, 2023. Because the Schedule presents only a selected portion of the Company's revenue, it is not intended to and does not present the financial position, changes in net deficit or cash flows of the Company. De Minimis Rate Used: N Rate Explanation: The Company has not elected to use the 10% de minimis indirect cost rate. For the HHS award related to the Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution program (the Program), HHS has indicated the amounts on the Schedule be reported corresponding to reporting requirements of the Health Resources and Services Administration (HRSA) Reporting Portal for the Program. Payments from HHS for the Program are assigned to "Payment Received Periods" (each, a Period) based upon the date each payment was received. Each Period has a specified Period of Availability and timing of reporting requirements. Entities report into the HRSA Reporting Portal for the Program after each Period's deadline to use the funds (i.e., after the end of the Period of Availability). The Schedule includes $827,345 received from HHS between January 2021 through December 31, 2021. In accordance with guidance from HHS, these amounts are presented as Period 3 and Period 4, respectively. Such amounts were recognized as other revenues in the Company’s financial statements as shown in the Schedule in the years ended March 31, 2021 and 2022. The Schedule includes the following entities that received the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution program: Legal Entity Name Tax Identification Number North Hill Home Health Care, Inc.. 45-4336870 North Hill Needham, Inc. 04-2716090
Title: Subsequent Events Accounting Policies: Basis of Presentation The accompanying Schedule of Other Revenues of HHS Award (the Schedule) is prepared in accordance with accounting principles generally accepted in the United States of America and the requirements of Title 45 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule includes revenue of the HHS Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution program of the Company for the periods of availability which ended in the year ended March 31, 2023. Because the Schedule presents only a selected portion of the Company's revenue, it is not intended to and does not present the financial position, changes in net deficit or cash flows of the Company. De Minimis Rate Used: N Rate Explanation: The Company has not elected to use the 10% de minimis indirect cost rate. The Company evaluated subsequent events for recognition or disclosure through January 2, 2024, the date the Schedule was available to be issued.

Finding Details

Finding 2023-001: Significant Deficiency in Internal Control Over Compliance - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting Assistance Listing Number: 93.498 - COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Award Number/Year: N/A/2021 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Recipients of Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution payments (the Program) must also comply with the reporting requirements described in the Program terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services.   Condition/Context: During our testing of the Period 3 and 4 reports, we noted that the Company did not calculate and report lost revenues in accordance with the U.S. Department of Health and Human Services guidance. Specifically, the Company inadvertently excluded certain amounts related to resident services. Additionally, they incorrectly included other operating revenues that were not related to providing resident services. The adjustment needed to correct the actual revenues decreased total lost revenues from $902,099 to $688,775, of which $216,203 was used in a prior reporting resulting in total lost revenues available to be used in the Period 4 of $472,571. The Company used $213,307 of lost revenues in Period 4 resulting in $259,264 of unused lost revenues available for future reporting periods. This is not a statistically valid sample. Effect: The amounts reported to Health Resources and Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Questioned Costs: None reported. Cause: An oversight during the review process that failed to identify the errors. Recommendation: We recommend that management revisit their review process to ensure that amounts are reconciled back to the general ledger during the review process. View of Responsible Officials: The Company agrees with the finding. The Company will implement a process for a member of the finance staff to prepare lost revenues calculations. The Director of Finance will then provide a second layer of detailed review of the lost revenue calculations and the financial reporting to ensure amounts captured are accurate and categorized appropriately. Sign off on preparation and review will be documented appropriately.
Finding 2023-001: Significant Deficiency in Internal Control Over Compliance - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting Assistance Listing Number: 93.498 - COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Award Number/Year: N/A/2021 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Recipients of Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution payments (the Program) must also comply with the reporting requirements described in the Program terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services.   Condition/Context: During our testing of the Period 3 and 4 reports, we noted that the Company did not calculate and report lost revenues in accordance with the U.S. Department of Health and Human Services guidance. Specifically, the Company inadvertently excluded certain amounts related to resident services. Additionally, they incorrectly included other operating revenues that were not related to providing resident services. The adjustment needed to correct the actual revenues decreased total lost revenues from $902,099 to $688,775, of which $216,203 was used in a prior reporting resulting in total lost revenues available to be used in the Period 4 of $472,571. The Company used $213,307 of lost revenues in Period 4 resulting in $259,264 of unused lost revenues available for future reporting periods. This is not a statistically valid sample. Effect: The amounts reported to Health Resources and Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Questioned Costs: None reported. Cause: An oversight during the review process that failed to identify the errors. Recommendation: We recommend that management revisit their review process to ensure that amounts are reconciled back to the general ledger during the review process. View of Responsible Officials: The Company agrees with the finding. The Company will implement a process for a member of the finance staff to prepare lost revenues calculations. The Director of Finance will then provide a second layer of detailed review of the lost revenue calculations and the financial reporting to ensure amounts captured are accurate and categorized appropriately. Sign off on preparation and review will be documented appropriately.