Finding 1236900 (2025-001)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-09-28
Audit: 412335
Auditor: EY

AI Summary

  • Core Issue: The Hospital mistakenly included unpaid pharmacy costs in FEMA reimbursement requests, leading to an overstatement of reported expenses.
  • Impacted Requirements: Compliance with 2 CFR sections 200.303 and 200.403, which mandate proper internal controls and documentation for allowable costs under federal awards.
  • Recommended Follow-Up: Implement additional verification steps in the pharmacy cost reporting process to ensure only incurred costs are submitted for reimbursement.

Finding Text

Finding COVID-19 – 2025-001 Allowable Costs/Cost Principles Identification of the federal program: Federal agency: U.S. Department of Homeland Security Pass-through program from: State of New York Division of Homeland Security and Emergency Services Federal Assistance Listing Number: 97.036 COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Contract/pass-through entity identifying number: 140215 Award period of performance: January 20, 2020 – July 1, 2022 Criteria or specified requirement (including statutory, regulatory, or other citation): 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish, document and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The 2 CFR section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal awards should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Section III – Federal Award Findings and Questioned Costs (continued) 2 CFR section 200.403 states the following: “Costs must meet the following criteria to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; (c) be consistent with policies and procedures that apply uniformly to both federally- financed and other activities of the non-Federal entity; (d) be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; (e) be determined in accordance with generally accepted accounting principles; (f) not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; (g) be adequately documented; and (h) administrative closeout costs may be incurred until the due date of the final report(s), liquidated prior to the due date of the final report(s) and charged to the final budget period of the award unless otherwise specified by the Federal agency. All other costs must be incurred during the approved budget period.” Condition: The New York and Presbyterian Hospital (the Hospital) has processes and internal controls in place to ensure that costs submitted to the Federal Emergency Management Agency (FEMA) in relation to the Disaster Grants – Public Assistance program were eligible under FEMA’s provisions and were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the costs to ensure the costs comply with the terms and conditions of the award. However, the Hospital’s internal controls did not identify that management inadvertently included certain pharmacy costs under project number 140215 that were not paid by the Hospital. Cause: Pharmacy costs include a very high volume of primarily low cost items and, as a result, a separate process was developed by the Hospital for accumulating such activity as compared to other costs that were submitted to FEMA for reimbursement. When compiling pharmacy costs for project number 140215, management utilized the pharmacy cost information derived from a report from its materials management system detailing purchase orders that were placed by the Hospital with its primary vendor for medications and supplies used in the treatment of patients during the COVID-19 pandemic. In the normal course of business, the pharmacy vendor may modify the fulfillment of purchase orders for medications and supplies that are not available or are available at different quantities than requested in the purchase order. The Hospital’s internal controls specific to this pharmacy activity did not include a step for management to verify that the costs derived from the report detailing purchase orders placed (which were submitted for FEMA reimbursement) were actually paid. Effect or potential effect: Due to the above, the Hospital included certain costs under project number 140215 that were not paid. Accordingly, there is an overstatement of the total pharmacy costs reported in project number 140215, and the Hospital was reimbursed by FEMA for certain costs that it did not incur, resulting in questioned costs. Questioned costs: Known questioned costs observed in the audit sample selections totaled $235. This amount represents the difference between the amount reimbursed by FEMA and the amount paid by the Hospital for certain pharmacy costs to the specific vendor. Based on the audit procedures performed, likely questioned costs exceed $25,000. Context: During our testing of expenditures underlying FEMA project number 140215, we selected a random sample of 60 expenditures and 5 key item expenditures from the project period (activity during 2020 – 2022) related to FEMA obligations that were approved in calendar year 2025. In our tests of compliance and internal controls over compliance, we identified certain expenditures for activity with the specific pharmacy vendor that were included under project number 140215 (and subsequently paid to the Hospital by FEMA) that were not incurred and expended by the Hospital. For 4 of the sample items tested, the amount reimbursed exceeded the actual amount paid by approximately $235. The terms and conditions of the FEMA award require recipients to submit eligible costs incurred and paid, thus this issue results in questioned costs and a control deficiency. The total FEMA expenditures for project number 140215 reported on the Hospital’s Schedule of Expenditures of Federal Awards for the year ended December 31, 2025 is $340,396,170, which includes approximately $12.5 million of total costs submitted related to the specific pharmacy vendor referred to above. Management performed a further review of pharmacy cost activity for the specific vendor as a result of this issue and determined that likely questioned costs for certain items that were submitted exceed $25,000. Management also informed us that they identified certain eligible costs from the applicable period that were not submitted for FEMA reimbursement and therefore were not reimbursed. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should consider the control deficiency described above to the extent there is applicability to other FEMA submissions or other federal programs in the future. Additionally, management should address with FEMA and remediate as appropriate the noncompliance for reimbursed amounts that were not expended by the Hospital. View of responsible officials: Management agrees with the finding.

Corrective Action Plan

Finding COVID-19 – 2025-001 Allowable Costs/Cost Principles Information on the federal program: Federal agency: U.S. Department of Homeland Security Pass-through program from: State of New York Division of Homeland Security and Emergency Services Federal Assistance Listing Number: 97.036 COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Contract/pass-through entity identifying number: 140215 Award period of performance: January 20, 2020 – July 1, 2022 Planned corrective action: COVID-19-eligible pharmacy costs consisted of a high volume of lower-cost items and were identified through a process distinct from other cost categories. Cost data were obtained from NYP’s materials management system, which records purchase orders placed with primary vendors for medications and supplies. NYP submitted for FEMA reimbursement only those medication costs identified as related to the treatment of patients during the COVID-19 pandemic. Pharmacy vendors may adjust purchase orders when medications or supplies are unavailable or available in quantities different from those requested. The internal control process for the pharmacy portion of NYP’s COVID-19 submissions did not verify that purchase orders were fulfilled as recorded, supported by vendor invoices and receipt documentation, and paid before the associated costs were included in reimbursement claims. Going forward, designated Finance and Pharmacy personnel will reconcile purchase orders to vendor invoices, receipt records, and proof of payment before submission; exceptions will be resolved and documented, and management will periodically review the control’s operation to confirm that only eligible, incurred, and paid costs are claimed. Name of responsible officials: Richard Einwechter Vice President, Financial Operations (212) 585-6589 rie9001@nyp.org Gary Sorkin Vice President Insurance and Risk Management (212) 297-5714 gas9063@nyp.org

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $19.29M
16.575 CRIME VICTIM ASSISTANCE $1.77M
93.686 ENDING THE HIV EPIDEMIC: A PLAN FOR AMERICA €” RYAN WHITE HIV/AIDS PROGRAM PARTS A AND B $995,598
93.884 PRIMARY CARE TRAINING AND ENHANCEMENT $680,815
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $573,594
93.153 COORDINATED SERVICES AND ACCESS TO RESEARCH FOR WOMEN, INFANTS, CHILDREN, AND YOUTH $549,088
93.939 HIV PREVENTION ACTIVITIES NON-GOVERNMENTAL ORGANIZATION BASED $463,384
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $441,210
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $429,933
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $405,000
93.217 FAMILY PLANNING SERVICES $402,389
93.778 GRANTS TO STATES FOR MEDICAID $370,642
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $226,843
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $124,800
93.940 HIV PREVENTION AND SURVEILLANCE ACTIVITIES-HEALTH DEPARTMENT BASED $124,745
93.395 CANCER TREATMENT RESEARCH $90,350
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $76,301
93.924 RYAN WHITE HIV/AIDS PROGRAM DENTAL REIMBURSEMENT AND COMMUNITY BASED DENTAL PARTNERSHIP GRANTS $72,079
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $53,846
93.837 CARDIOVASCULAR DISEASES RESEARCH $38,811
93.761 EVIDENCE-BASED FALLS PREVENTION PROGRAMS FINANCED SOLELY BY PREVENTION AND PUBLIC HEALTH FUNDS (PPHF) $31,185
93.853 EXTRAMURAL RESEARCH PROGRAMS IN THE NEUROSCIENCES AND NEUROLOGICAL DISORDERS $30,000
93.RD Newborn Screening Follow-up Study of Congenital Cytomegalovirus (cCMV) Infection $27,593
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $24,600
93.361 NURSING RESEARCH $18,483
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $15,007