Finding 1161064 (2021-004)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
$1
Year
2021
Accepted
2025-10-20
Audit: 371035

AI Summary

  • Core Issue: Expenditures reported to HRSA were overstated due to improper calculations and duplicate employee expenses.
  • Impacted Requirements: Reporting did not comply with Pub. L. No. 116-136, leading to questioned costs of $1,883,051.
  • Recommended Follow-Up: Establish documented internal controls for accurate reporting and review of program expenditures before submission.

Finding Text

Federal Program – COVID-19 – Provider Relief Fund, ALN 93.498, Award Year 2021 Criteria or Specific Requirement – Activities Allowed/Allowable Costs and Reporting – Pub. L. No. 116-136, 134 Stat. 563 Condition – Expenditures reported to HRSA were not in accordance with Pub. L. No. 116-136, 134 Stat. 563. Questioned Costs – $1,828,575 was the amount of expenses determined to be over-reported to the federal program due to failure to reduce expenses by the Authority’s Medicare cost reimbursement percentage. This was calculated by multiplying total Provider Relief Fund expenses reported to HRSA for Period 1 by the Authority ($3,265,896) by the Authority’s Medicare cost reimbursement percentage (55.99%). Additionally, $55,476 was the amount determined to be over-reported to the federal program due to the inclusion of certain employee bonus expenses twice or the Authority’s inability to provide support for the expenditure. Context – The Authority did not reduce expenses included in the Authority’s portal submission by its Medicare cost reimbursement percentage resulting in a testing population that did not agree to expenses reported. Additionally, some employee expenses were included twice. Effect – Expenditures reported to HRSA were overstated. Cause – The Authority did not have effective internal control processes in place to ensure the accurate review and reporting of program expenditures. Changes to frequently asked questions and guidance from HRSA and management’s inexperience with the program requirements resulted in an error of expenditures under the program. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The Authority should implement documented internal control processes specific to understanding the reporting of program expenditures, including review and oversight of data uploads prior to submission. Views of Responsible Officials and Planned Corrective Actions – The Authority will continue to monitor the Department of Health and Human Resources Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements and believes that it has sufficient additional unclaimed expenses and lost revenues to support the Provider Relief Funds received.

Corrective Action Plan

Condition - Expenditures reported to HRSA were not in accordance with Pub. L. No. 116-136, 134 Stat. 563 Plan of Corrective Action Much research was performed by the Authority's leadership to identify guidance from HRSA including reviewing FAQs, Fact Sheets, consulting attorneys, auditors, consultants and other parties. The complexity of the reporting requirements, including changing FAQ's and our inability to gain a definite approval of the use of our funds, resulted in the Authority filing the its submission based on the best available information at the time. The Authority's position is that the Provider Relief Funds were appropriately expensed using additional expenses and lost revenues not initially submitted to the portal. The Authority will continue to monitor the guidance for use of funds provided by HRSA and will strive to appropriately utilize all funds in the future. The Authority will review the most recently distributed Provider Relief Fund FAQ's which provide details on requirements related to the program Contact person: Chris Martin, CEO cmartin@ccghospital.com (580)927-2327 Expected implementation:2024 - 2025

Categories

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management Reporting Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $3.72M
93.301 Covid-19 - Small Rural Hospital Improvement Grant Program $78,499
21.019 Covid-19 - Coronavirus Relief Fund $59,880
93.889 National Bioterrorism Hospital Preparedness Program $11,752
93.301 Small Rural Hospital Improvement Grant Program $10,077