Finding 2023-001
Federal Program Information
Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA)
Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Award Period of Performance: ...
Finding 2023-001
Federal Program Information
Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA)
Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Award Period of Performance: July 1, 2020 to June 30, 2023
Corrective Action Planned:
Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances.
As it relates to the COVID Activity Code, this code was created as a means to track certain COVID hours worked, but was not configured to calculate the amounts associated with those hours, resulting in the need to make reasonable estimates. Even using the base pay rate at the time the hours were incurred would not have been accurate since it would omit adjustments for shift differentials, weekend hours, and overtime. We performed internal analyses and reviewed the results of samples selected by the auditors and concluded that the risk of a material overcharge to the program was minimal. Further, we have almost $40 million of unused lost revenues after our final PRF submission for Period 5, such that any questioned costs would easily be covered by other eligible uses of PRF funds.
We have reviewed our processes related to the retention of expense documentation to improve audit evidence should this program ever be awarded in future periods.
Responsible party: Lee Sonne, Vice President of Finance and Controller
Implementation Date: Procedures were reviewed and analysis completed along with the Period 5 portal filing in September 2023.