Finding 1176707 (2021-004)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2021
Accepted
2026-03-06
Audit: 390602
Organization: Beartooth Billings Clinic (MT)

AI Summary

  • Core Issue: The Organization reported COVID-19 expenses totaling $179,935 outside the allowed time frame for the Provider Relief Fund.
  • Impacted Requirements: Compliance with federal reporting criteria (45 CFR 75.342) and proper documentation of allowable costs as per HHS guidelines.
  • Recommended Follow-Up: Enhance understanding of HHS guidance and collaborate with external advisors to ensure accurate reporting before future submissions.

Finding Text

Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Assistance Listing No. 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) U.S. Department of Health and Human Services Criteria or Specific Requirement – Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, P.L. 116-136) to reimburse, through grants or other mechanisms, eligible health care providers for increased expenses or lost revenue attributable to Coronavirus Disease 2019 (COVID-19). Entities that receive more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. In addition, the Organization is required to implement and maintain internal controls over financial reporting. Condition – The Organization reported COVID-19-related expenditures that were outside the Period of Availability according to the Health and Human Services (HHS) FAQ for Provider Relief Fund (PRF) Questioned Costs – $179,935 was the total amount of expenses determined to be over-reported to the federal program. Context – Upon testing the compliance requirements of this program, it was determined that the expenditure items were outside the period of availabilty as is consistent with existing guidance provided by HHS. Effect – The Organization submitted expenses under the PRF program that are outside of the period of availibility. Cause – The guidance provided by HHS to providers across the country as to how to report their COVID-19-related expenses and lost revenues is, at times, difficult to comprehend and apply. The Organization incorrectly applied guidance. Identification as a Repeat Finding – Not a repeat finding Recommendation – The Organization should continue to improve its understanding of the guidance related to this type of reporting and work with their external advisors to identify areas for improvement prior to submission to the Provider Relief Fund Reporting portal. View of Responsible Official and Planned Corrective Actions – The Organization agrees with the finding. See separate report for planned corrective actions

Corrective Action Plan

Capital expenditures charged to the PRF program were allowable; however, at June 30, 2021, HHS had not yet issued clear technical guidance indicating that capital costs must be fully completed or received within the Period of Availability, therefore causing the expenditures to be out of period. Definitive guidance clarifying this requirement was not released until August 2021, after the close of the reporting period. As a result, the Organization applied the best available interpretation at the time of close. To prevent similar issues, the Organization will incorporate ongoing monitoring of updated directives, strengthen pre submission technical reviews, and consult with external advisors to validate compliance with period of availability rules prior to future filings.

Categories

Allowable Costs / Cost Principles Cash Management Period of Performance Reporting

Other Findings in this Audit

  • 1176706 2021-003
    Material Weakness Repeat
  • 1176708 2021-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 PROVIDER RELIEF FUND AND AMERICAN RESCUE PLAN (ARP) RURAL DISTRIBUTION $3.60M