Program name: State and Local Fiscal Recover Funds Assistance Listing: 21.027, 14.239, 14,231 Federal award Identification number: All Federal award year: All Federal awarding agency: U.S. Department of Treasury and U.S. Department of Housing and Urban Development Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that include the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor's responsibility under 2 CFR 200.518 major program determination and for federal oversight. Condition: The Organization failed to include the correct amount of expenditures and the ALN numbers. The awards were identified as federal during the current audit; however, the Organization failed to include the ALN in the current year’s SEFA. After additional inquiry and evaluation, they were determined to fall under ALN 14.239, 14.231 and 21.027. Cause: There were deficiencies in the Organizations's internal controls over the SEFA preparation, specifically identifying the current ALN number for each federal award. The absence of the assistance listing number indicates inadequate review and verification procedures. Effect or Potential Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Missing ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. Repeat finding: This is not a repeat finding. Perspective: This issue affected three federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs. Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance Requirements. Management’s response and corrective action plan (unaudited): See corrective action plan
Federal Program(s): Enhanced Mobility of Seniors and Individuals with Disabilities (ALN 20.513) Agencies: U.S. Department of Transportation – Federal Transit Administration Criteria - 2 CFR §200.510: Auditee must prepare an accurate SEFA including ALN, program name, award number, award year, pass-through number, and total expenditures. 2 CFR §200.332: Pass-through entities must identify the ALN in all subaward documents. 2 CFR §200.303: Auditees must establish and maintain effective internal controls over federal awards. Condition - During our audit of ENVIDA’s federal programs, we identified an internal control deficiency affecting the accuracy of the Schedule of Expenditures of Federal Awards (SEFA). Context - The issue stems from the Envida's need to formalize documented procedures and adequate review over the SEFA preparation process, as well as the need to implement controls for verifying federal award information received from pass-through entities. Specifically, ENVIDA’s SEFA included initial misstatements, including erroneous reporting of $61,576 in required matched funds as federal expenditures (which they were not), the inclusion of $79,225 in OnDemand expenditures that were not federally funded (incorrect information from passthrough entity), and a $45,403 posting error that misclassified expenditures between grant years. These errors resulted in a material overstatement of the SEFA federal expenditures as originally prepared. Management corrected these errors during the audit process. Cause - Due to lack of funding information provided in the contracts with a major passthrough entity, Envida is unable to verify accuracy of federal funding information contemporaneously. For 2024, incomplete or inaccurate information from pass-through entities, coupled with the absence of formalized internal controls to verify and document federal award details, led to initial errors in SEFA reporting. Contracts with the pass-through entity, Pikes Peak Area Council of Governments (PPACG), did not include the required Assistance Listing Numbers (ALNs), which contributed to the confusion and misreporting. These deficiencies are inconsistent with the requirements of 2 CFR §200.510(b), §200.303, and §200.332(a)(1), which collectively mandate accurate SEFA reporting, proper identification of federal awards, and internal controls over federal funding. Effect - SEFA initially overstated by 15.5% due to match and OnDemand errors. FY24 award overstated by 17.5%; FY25 award understated by 14.6% Potential audit coverage gaps and risk misassessment under 2 CFR §200.518. Recommendation - We recommend that ENVIDA establish and document clear procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) as well as for the proper classification of accounts receivable. In addition, ENVIDA should implement a supervisory review process to help ensure accuracy and compliance with federal requirements. To further strengthen controls, all subaward agreements should require written confirmation of the Assistance Listing Numbers (ALNs). Finally, ENVIDA should verify federal award information directly against official federal award notices prior to preparing the SEFA. Views of Responsible Official and Planned Corrective Action - Management has agreed with the finding and plans to revise the SEFA to reflect accurate federal expenditures. They will work with pass-through entities to ensure future subaward documentation includes all required federal award identifiers and will implement internal controls to prevent recurrence.
Criteria Under the American Rescue Plan Act of 2021, as implemented by the U.S. Department of the Treasury through 31 CFR Part 35 and the 2022 Final Rule, SLFRF recipients must establish and maintain effective internal controls to ensure that funds are used for eligible purposes and that eligibility determinations are based on substantiated, risk-mitigated criteria. The 2024 SLFRF Compliance Supplement designates the program as “higher risk,” requiring enhanced scrutiny of eligibility and fraud prevention measures. Condition The program relied extensively on self-attestation by applicants as the standard method of verifying eligibility, without requiring supporting documentation or conducting verification procedures. These practices were applied broadly and not limited to exceptional cases. Cause Program administrators adopted simplified eligibility procedures including approved use of geographic indicators such as zip codes to expedite benefit delivery. However, they did not implement compensating controls or verification mechanisms to mitigate the increased risk of fraud and ineligible payments associated with self-attestation and geographic proxies. Effect The use of self-attestation as primary eligibility tools may result in: • Ineligible recipients receiving benefits. • Disparate treatment of similarly situated individuals outside designated ZIP codes. • Increased fraud risk, particularly in a program already designated as high-risk. • Noncompliance with federal eligibility and internal control requirements under Uniform Guidance (2 CFR §200.303 and §200.518). Questioned Costs Estimated questioned costs include: • One Hundred Twenty-Six loan disbursements and grant awards using self-attestation eligibility criteria: $1,983,326. Recommendation The entity should: 1. Reassess eligibility criteria to ensure they are substantiated, equitable, and compliant with federal requirements. 2. Limit self-attestation to exceptional cases and implement verification procedures for all standard applications. 3. Strengthen internal controls to detect and prevent fraud, including random audits, third-party verification, and data cross-checks. 4. Document eligibility determinations and maintain records to support compliance with SLFRF rules and audit standards. Views of Responsible Officials The Foundation recognizes that self-attestation regarding impact of the Covid pandemic carries some fraud risk. The self-attestation process was developed as directed by the Washington Department of Commerce (the state recipient that contracted with the Foundation) to permit businesses not located in a geographic area that was presumptively disproportionately affected by the pandemic to participate in the program. Participants were required to explain the pandemic impact that they suffered in sufficient detail as to allow verification. The process attempted to balance fraud prevention against the desire to streamline qualification and reduce barriers to participation. The Foundation recognizes that documentation of the evidence of pandemic related impacts for self-attestation borrowers could be better.
Finding 2024-001: Reportable finding considered a significant deficiency - Inaccurate and Incomplete Schedule of Expenditures of Federal Awards (SEFA) and Delay in Reporting Program names: ARPA Workforce development and Workforce Innovation and Opportunity Act (WIOA) Adult 24-25 - Cluster Assistance Listings and Award Number: 21.027 (24-25 ACWDB-MP-01) and 17.258 (24343) Federal awarding agency: United States Department of the Treasury for American Rescue Plan Act (ARPA) of 2021 and United States Department of Labor Pass-through Entities: Alameda County Workforce Development Board and City of Oakland Workforce Development Board Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that includes the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor’s responsibility under 2 CFR 200.518 major program determination and for federal oversight. In addition this error resulted in a delay in financial reporting. 2 CFR §200.512(b) requires that the Uniform Guidance report be submitted "no later than 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period," whichever comes first. Timely reporting is essential for compliance with federal grant requirements and for maintaining eligibility for future funding. Condition: The Organization failed to include two federal pass-through awards received from state and local governmental entities in the current years’ SEFA. These awards were only identified as federal during the current audit year. After additional inquiry, they were determined to fall under ALN 21.027 and 17.258. Cause: There were deficiencies in the Organization’s internal controls over SEFA preparation, specifically in identifying, classifying, and documenting pass-through federal awards. The absence of award documentation and misclassification of the assistance listing number further indicate inadequate review and verification procedures. Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Misreporting ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. In addition the error resulted in a delay in financial reporting. Repeat finding: This is not a repeat finding. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: Implement procedures to require written documentation (e.g., subaward agreements) for all federal pass-through funding received. Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs and funding sources. Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance requirements.
Finding 2024-003: Reportable finding considered a significant deficiency - Inaccurate and Incomplete Schedule of Expenditures of Federal Awards (SEFA) Program name: Child and Adult Care Food Program Assistance Listing: 10.558 Federal awarding agency: U.S. Department of Agriculture (USDA) Pass-through Entity: Maryland State Department of Education, District of Columbia Education Office Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that includes the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor’s responsibility under 2 CFR 200.518 major program determination and for federal oversight. Condition: The Organization failed to include two federal pass-through awards received from state and local governmental entities in prior years’ SEFAs. These awards were only identified as federal during the current audit year. Furthermore, when the awards were initially included in the current year’s SEFA, they were incorrectly classified under ALN 10.555 (National School Lunch Program). After additional inquiry and evaluation, they were determined to fall under ALN 10.558 (Child and Adult Care Food Program). The Organization was unable to locate specific subaward agreements; only a master service agreement from the state government was available. Cause: There were deficiencies in the Organization’s internal controls over SEFA preparation, specifically in identifying, classifying, and documenting pass-through federal awards. The absence of award documentation and misclassification of the assistance listing number further indicate inadequate review and verification procedures. Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Misreporting ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. Repeat finding: This is not a repeat finding. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: • Implement procedures to require written documentation (e.g., subaward agreements) for all federal pass-through funding received. • Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs and funding sources. • Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance requirements. Management’s response and corrective action plan (unaudited): See corrective action plan.
Finding 2024-003: Reportable finding considered a significant deficiency - Inaccurate and Incomplete Schedule of Expenditures of Federal Awards (SEFA) Program name: Child and Adult Care Food Program Assistance Listing: 10.558 Federal awarding agency: U.S. Department of Agriculture (USDA) Pass-through Entity: Maryland State Department of Education, District of Columbia Education Office Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that includes the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor’s responsibility under 2 CFR 200.518 major program determination and for federal oversight. Condition: The Organization failed to include two federal pass-through awards received from state and local governmental entities in prior years’ SEFAs. These awards were only identified as federal during the current audit year. Furthermore, when the awards were initially included in the current year’s SEFA, they were incorrectly classified under ALN 10.555 (National School Lunch Program). After additional inquiry and evaluation, they were determined to fall under ALN 10.558 (Child and Adult Care Food Program). The Organization was unable to locate specific subaward agreements; only a master service agreement from the state government was available. Cause: There were deficiencies in the Organization’s internal controls over SEFA preparation, specifically in identifying, classifying, and documenting pass-through federal awards. The absence of award documentation and misclassification of the assistance listing number further indicate inadequate review and verification procedures. Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Misreporting ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. Repeat finding: This is not a repeat finding. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: • Implement procedures to require written documentation (e.g., subaward agreements) for all federal pass-through funding received. • Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs and funding sources. • Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance requirements. Management’s response and corrective action plan (unaudited): See corrective action plan.
Finding 2024-003: Reportable finding considered a significant deficiency - Inaccurate and Incomplete Schedule of Expenditures of Federal Awards (SEFA) Program name: Child and Adult Care Food Program Assistance Listing: 10.558 Federal awarding agency: U.S. Department of Agriculture (USDA) Pass-through Entity: Maryland State Department of Education, District of Columbia Education Office Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that includes the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor’s responsibility under 2 CFR 200.518 major program determination and for federal oversight. Condition: The Organization failed to include two federal pass-through awards received from state and local governmental entities in prior years’ SEFAs. These awards were only identified as federal during the current audit year. Furthermore, when the awards were initially included in the current year’s SEFA, they were incorrectly classified under ALN 10.555 (National School Lunch Program). After additional inquiry and evaluation, they were determined to fall under ALN 10.558 (Child and Adult Care Food Program). The Organization was unable to locate specific subaward agreements; only a master service agreement from the state government was available. Cause: There were deficiencies in the Organization’s internal controls over SEFA preparation, specifically in identifying, classifying, and documenting pass-through federal awards. The absence of award documentation and misclassification of the assistance listing number further indicate inadequate review and verification procedures. Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Misreporting ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. Repeat finding: This is not a repeat finding. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: • Implement procedures to require written documentation (e.g., subaward agreements) for all federal pass-through funding received. • Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs and funding sources. • Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance requirements. Management’s response and corrective action plan (unaudited): See corrective action plan.
Finding 2024-003: Reportable finding considered a significant deficiency - Inaccurate and Incomplete Schedule of Expenditures of Federal Awards (SEFA) Program name: Child and Adult Care Food Program Assistance Listing: 10.558 Federal awarding agency: U.S. Department of Agriculture (USDA) Pass-through Entity: Maryland State Department of Education, District of Columbia Education Office Criteria: In accordance with 2 CFR 200.510(b), the auditee must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) that includes the total federal awards expended for each federal program, the assistance listing number (ALN), the name of the federal agency, and the pass-through entity identifying number. Accurate SEFA reporting is essential to support the auditor’s responsibility under 2 CFR 200.518 major program determination and for federal oversight. Condition: The Organization failed to include two federal pass-through awards received from state and local governmental entities in prior years’ SEFAs. These awards were only identified as federal during the current audit year. Furthermore, when the awards were initially included in the current year’s SEFA, they were incorrectly classified under ALN 10.555 (National School Lunch Program). After additional inquiry and evaluation, they were determined to fall under ALN 10.558 (Child and Adult Care Food Program). The Organization was unable to locate specific subaward agreements; only a master service agreement from the state government was available. Cause: There were deficiencies in the Organization’s internal controls over SEFA preparation, specifically in identifying, classifying, and documenting pass-through federal awards. The absence of award documentation and misclassification of the assistance listing number further indicate inadequate review and verification procedures. Effect: Incomplete and inaccurate SEFA reporting may lead to noncompliance with Uniform Guidance requirements and increases the risk of omitted or misclassified programs subject to audit. Misreporting ALNs may also hinder proper audit coverage and oversight by federal and pass-through entities. Repeat finding: This is not a repeat finding. Questioned costs: There are no questioned costs associated with this finding. Perspective: This issue affected two federal awards and represents a systemic control issue over SEFA preparation. There is a reasonable possibility that similar issues could recur if not addressed. Recommendation: We recommend that the Organization: • Implement procedures to require written documentation (e.g., subaward agreements) for all federal pass-through funding received. • Enhance internal controls over the SEFA preparation process to ensure federal programs are accurately identified, classified, and reported, including verification of ALNs and funding sources. • Designate responsibility within the finance team for verifying the federal nature of all awards and ensure ongoing training on SEFA and Uniform Guidance requirements. Management’s response and corrective action plan (unaudited): See corrective action plan.
Disclaimer of Opinion relating to ALN#93.498 COVID-19 Provider Relief Funds (PRF) and American Rescue Plan (ARP)—MHS Condition—The accompanying Schedule of Expenditures of Federal Awards (“SEFA”) includes the COVID-19 Provider Relief Funds and American Rescue Plan (“PRF”) programs for Monongalia Health System, Inc (MHS), which was acquired by the System in September 2022. It is appropriate for MHS’s PRF to be included on the consolidated SEFA as of December 31, 2023. However, PRF are unique in that the compliance requirements apply to MHS operational results from prior periods which predate the business acquisition and were audited by other auditors. As such, the MHS PRF is unaudited. Effect—The auditors are faced with practical challenges to access all the financial records or obtain sufficient corroborative evidence from these periods before the acquisition. Consequently, we were unable to obtain sufficient appropriate audit evidence for the direct and material compliance requirements and therefore, we were unable to perform any audit procedures on the COVID-19 Provider Relief funds and American Rescue Plan program related to MHS as of December 31, 2023, and we do not express an opinion on the compliance of MHS with the specific requirements of PRF. Cause—Monongalia Health System, Inc (MHS) was acquired by the System in September 2022. As an acquired entity, MHS changed its fiscal year end from June 30th to December 31st to align with the System’s fiscal year-end. MHS was officially consolidated with the System’s financial statements since. Therefore, there are practical challenges to report the PRF balances reportable on the December 31, 2023 SEFA as the lost revenues and expenditures relate to periods audited by the predecessor auditor. Criteria—Based on CFR § 200.518 Major program determination, MHS’s PRF program is classified as a high-risk type A program and therefore, a major program. However, due to the circumstances detailed above, the auditors are not able to issue an opinion for the program. Context/Perspective—This issue is isolated to MHS PRF funds that were reportable as a of December 31, 2023 as the underlying lost revenue and expenses related to periods prior to the System’s acquisition of MHS on September 1, 2022. As there is no clear guidance in member substitution transactions that cross over reporting periods, the System has included the program on the SEFA; however, the auditors were unable to audit the program. Questioned Costs—There were approximately $6,469,944 of MHS PRF monies reported on the SEFA. Recommendation—We recommend that the System obtain approval from department of HHS and other regulatory authorities and agree to a path forward when member substitutions arise to determine the most appropriate reporting treatment and allow for a practical audit of funds.
Disclaimer of Opinion relating to ALN#93.498 COVID-19 Provider Relief Funds (PRF) and American Rescue Plan (ARP)—MHS Condition—The accompanying Schedule of Expenditures of Federal Awards (“SEFA”) includes the COVID-19 Provider Relief Funds and American Rescue Plan (“PRF”) programs for Monongalia Health System, Inc (MHS), which was acquired by the System in September 2022. It is appropriate for MHS’s PRF to be included on the consolidated SEFA as of December 31, 2023. However, PRF are unique in that the compliance requirements apply to MHS operational results from prior periods which predate the business acquisition and were audited by other auditors. As such, the MHS PRF is unaudited. Effect—The auditors are faced with practical challenges to access all the financial records or obtain sufficient corroborative evidence from these periods before the acquisition. Consequently, we were unable to obtain sufficient appropriate audit evidence for the direct and material compliance requirements and therefore, we were unable to perform any audit procedures on the COVID-19 Provider Relief funds and American Rescue Plan program related to MHS as of December 31, 2023, and we do not express an opinion on the compliance of MHS with the specific requirements of PRF. Cause—Monongalia Health System, Inc (MHS) was acquired by the System in September 2022. As an acquired entity, MHS changed its fiscal year end from June 30th to December 31st to align with the System’s fiscal year-end. MHS was officially consolidated with the System’s financial statements since. Therefore, there are practical challenges to report the PRF balances reportable on the December 31, 2023 SEFA as the lost revenues and expenditures relate to periods audited by the predecessor auditor. Criteria—Based on CFR § 200.518 Major program determination, MHS’s PRF program is classified as a high-risk type A program and therefore, a major program. However, due to the circumstances detailed above, the auditors are not able to issue an opinion for the program. Context/Perspective—This issue is isolated to MHS PRF funds that were reportable as a of December 31, 2023 as the underlying lost revenue and expenses related to periods prior to the System’s acquisition of MHS on September 1, 2022. As there is no clear guidance in member substitution transactions that cross over reporting periods, the System has included the program on the SEFA; however, the auditors were unable to audit the program. Questioned Costs—There were approximately $6,469,944 of MHS PRF monies reported on the SEFA. Recommendation—We recommend that the System obtain approval from department of HHS and other regulatory authorities and agree to a path forward when member substitutions arise to determine the most appropriate reporting treatment and allow for a practical audit of funds.
Disclaimer of Opinion relating to ALN#93.498 COVID-19 Provider Relief Funds (PRF) and American Rescue Plan (ARP)—MHS Condition—The accompanying Schedule of Expenditures of Federal Awards (“SEFA”) includes the COVID-19 Provider Relief Funds and American Rescue Plan (“PRF”) programs for Monongalia Health System, Inc (MHS), which was acquired by the System in September 2022. Under the PRF federal reporting guidance, MHS’s PRF program should be included on the SEFA no earlier than fiscal year end of December 31, 2022. It is appropriate for MHS’s PRF to be included on the consolidated SEFA as of December 31, 2022. However, PRF are unique in that the compliance requirements apply to MHS operational results from prior periods which predate the business acquisition and were audited by other auditors. As such, the MHS PRF is unaudited. Effect—The auditors are faced with practical challenges to access all the financial records or obtain sufficient corroborative evidence from these periods before the acquisition. Consequently, we were unable to obtain sufficient appropriate audit evidence for the direct and material compliance requirements and therefore, we were unable to perform any audit procedures on the COVID-19 Provider Relief funds and American Rescue Plan program related to MHS as of December 31, 2022, and we do not express an opinion on the compliance of MHS with the specific requirements of PRF. Cause—Monongalia Health System, Inc (MHS) was acquired by the System in September 2022. As an acquired entity, MHS changed its fiscal year end from June 30th to December 31st to align with the System’s fiscal year-end. MHS was officially consolidated with the System’s financial statements as of fiscal year end December 31, 2022. Therefore, there are practical challenges to report the PRF balances reportable on the December 31, 2022 SEFA as the lost revenues and expenditures relate to periods audited by the predecessor auditor. Criteria—Based on CFR § 200.518 Major program determination, MHS’s PRF program is classified as a high-risk type A program and therefore, a major program. However, due to the circumstances detailed above, the auditors are not able to issue an opinion for the program. Context/Perspective—This issue is isolated to MHS PRF funds that were reportable as a of December 31, 2022 but the underlying lost revenue and expenses related to periods prior to the System’s acquisition of MHS on September 1, 2022. As there is no clear guidance in member substitution transactions that cross over reporting periods, the System has included the program on the SEFA; however, the auditors were unable to audit the program. Questioned Costs—There were approximately $7,051,383 of MHS PRF monies reported on the SEFA. Recommendation—We recommend that the System obtain approval from department of HHS and other regulatory authorities and agree to a path forward when member substitutions arise to determine the most appropriate reporting treatment and allow for a practical audit of funds. Views of Responsible Officials and Planned Corrective Action—Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.
Disclaimer of Opinion relating to ALN#93.498 COVID-19 Provider Relief Funds (PRF) and American Rescue Plan (ARP)—MHS Condition—The accompanying Schedule of Expenditures of Federal Awards (“SEFA”) includes the COVID-19 Provider Relief Funds and American Rescue Plan (“PRF”) programs for Monongalia Health System, Inc (MHS), which was acquired by the System in September 2022. Under the PRF federal reporting guidance, MHS’s PRF program should be included on the SEFA no earlier than fiscal year end of December 31, 2022. It is appropriate for MHS’s PRF to be included on the consolidated SEFA as of December 31, 2022. However, PRF are unique in that the compliance requirements apply to MHS operational results from prior periods which predate the business acquisition and were audited by other auditors. As such, the MHS PRF is unaudited. Effect—The auditors are faced with practical challenges to access all the financial records or obtain sufficient corroborative evidence from these periods before the acquisition. Consequently, we were unable to obtain sufficient appropriate audit evidence for the direct and material compliance requirements and therefore, we were unable to perform any audit procedures on the COVID-19 Provider Relief funds and American Rescue Plan program related to MHS as of December 31, 2022, and we do not express an opinion on the compliance of MHS with the specific requirements of PRF. Cause—Monongalia Health System, Inc (MHS) was acquired by the System in September 2022. As an acquired entity, MHS changed its fiscal year end from June 30th to December 31st to align with the System’s fiscal year-end. MHS was officially consolidated with the System’s financial statements as of fiscal year end December 31, 2022. Therefore, there are practical challenges to report the PRF balances reportable on the December 31, 2022 SEFA as the lost revenues and expenditures relate to periods audited by the predecessor auditor. Criteria—Based on CFR § 200.518 Major program determination, MHS’s PRF program is classified as a high-risk type A program and therefore, a major program. However, due to the circumstances detailed above, the auditors are not able to issue an opinion for the program. Context/Perspective—This issue is isolated to MHS PRF funds that were reportable as a of December 31, 2022 but the underlying lost revenue and expenses related to periods prior to the System’s acquisition of MHS on September 1, 2022. As there is no clear guidance in member substitution transactions that cross over reporting periods, the System has included the program on the SEFA; however, the auditors were unable to audit the program. Questioned Costs—There were approximately $7,051,383 of MHS PRF monies reported on the SEFA. Recommendation—We recommend that the System obtain approval from department of HHS and other regulatory authorities and agree to a path forward when member substitutions arise to determine the most appropriate reporting treatment and allow for a practical audit of funds. Views of Responsible Officials and Planned Corrective Action—Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.
Assistance Listing, Federal Agency, and Program Name - Assistance Listing 66.443, Environmental Protection Agency, Reducing Lead in Drinking Water Federal Award Identification Number and Year - OOE02968, 2021 Pass-through Entity - n/a Finding Type - Material weakness Repeat Finding - No Criteria - 2 CFR 200.508 requires the City to prepare appropriate financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510. The SEFA must list individual federal programs as required by 2 CFR 200.501(b)(1). The SEFA is the basis for the auditor determination of major programs as required by 2 CFR 200.518. Condition - The original SEFA prepared for audit purposes did not include all federal expenditures that should have been reported under ALN 66.443. Questioned Costs - None Identification of How Questioned Costs Were Computed - n/a Context - Approximately $864,000 of federal expenditures were not included in the original SEFA prepared for audit purposes under ALN 66.443. Cause and Effect - The City's controls over reconciling the SEFA to federal revenue did not detect the missing expenditures because federal revenue was not appropriately accrued by $864,000. As a result, ALN 66.443 was not originally identified as a major program. Recommendation - The City should review its controls over preparation of the SEFA and reconciling the SEFA to federal expenditures per the general ledger to ensure the appropriate amount of federal expenditures are reported on the SEFA. Views of Responsible Officials and Corrective Action Plan - We agree with the auditor’s recommendation. Changes have been implemented to ensure all programs with both federal and state/local funding will be examined to ensure correct expenditure by funding source is properly recorded.
Assistance Listing, Federal Agency, and Program Name - Assistance Listing 66.443, Environmental Protection Agency, Reducing Lead in Drinking Water Federal Award Identification Number and Year - OOE02968, 2021 Pass-through Entity - n/a Finding Type - Material weakness Repeat Finding - No Criteria - 2 CFR 200.508 requires the City to prepare appropriate financial statements, including the schedule of expenditures of federal awards (SEFA) in accordance with 2 CFR 200.510. The SEFA must list individual federal programs as required by 2 CFR 200.501(b)(1). The SEFA is the basis for the auditor determination of major programs as required by 2 CFR 200.518. Condition - The original SEFA prepared for audit purposes did not include all federal expenditures that should have been reported under ALN 66.443. Questioned Costs - None Identification of How Questioned Costs Were Computed - n/a Context - Approximately $864,000 of federal expenditures were not included in the original SEFA prepared for audit purposes under ALN 66.443. Cause and Effect - The City's controls over reconciling the SEFA to federal revenue did not detect the missing expenditures because federal revenue was not appropriately accrued by $864,000. As a result, ALN 66.443 was not originally identified as a major program. Recommendation - The City should review its controls over preparation of the SEFA and reconciling the SEFA to federal expenditures per the general ledger to ensure the appropriate amount of federal expenditures are reported on the SEFA. Views of Responsible Officials and Corrective Action Plan - We agree with the auditor’s recommendation. Changes have been implemented to ensure all programs with both federal and state/local funding will be examined to ensure correct expenditure by funding source is properly recorded.