Finding 12402 (2022-002)

-
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-06-29

AI Summary

  • Core Issue: The System incorrectly calculated third-party insurance deductions for FEMA funding, leading to an overstatement of their application.
  • Impacted Requirements: FEMA guidelines require that costs be reduced by all applicable credits, including accurate insurance proceeds.
  • Recommended Follow-up: Improve controls over insurance payment calculations and collaborate with MEMA and FEMA to assess potential reimbursements.

Finding Text

2022-002 ? Insurance payments not fully deducted from FEMA funding Cluster: Not applicable Grantor: U.S. Department of Homeland Security Award Names: COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Award Year: January 20, 2020 ? July 1, 2022 Award Number: 4496DR-MA Assistance Listing Numbers: 97.036 Pass-through entity: Massachusetts Emergency Management Agency (?MEMA?) Criteria FEMA guidance indicates that costs incurred as a result of an incident must be reduced by all applicable credits, such as insurance proceeds and salvage values (Stafford Act section 312, 42 USC section 5155 and 2 CFR section 200.406) Condition Through our testing of 60 direct costs associated with the System?s FEMA projects that were obligated in fiscal year 2022, 6 transactions totaling $1.4M were tested related to COVID-19 PCR tests that were purchased by the System from 2 vendors. These tests were administered to patients and System personnel and to the extent eligible, they were billed to the patients? or employees? third-party insurance company. As such, when compiling information for their FEMA application, the System completed an analysis showing total PCR tests purchased and the associated cost and deducted third-party insurance payments received associated with these PCR tests. The System calculated the third-party insurance deduction by developing an average third-party insurance payment rate per test. When performing our review of the average third-party insurance payment calculation, we noted management inappropriately included employee PCR tests not subject to reimbursement in the calculation of the average rate per test. As a result, management used an estimated average rate per test of $79 to calculate the third-party insurance deduction instead of an estimated average rate per test of $84. The impact of the change in average rate per test results in the System understating the third-party insurance payments by approximately $218,000. Cause Management?s review of the calculation did not identify the formula error in the calculation of the average payment rate per reimbursed PCR test. Effect The System?s FEMA application was overstated, resulting in an overpayment by FEMA related to the System?s PCR tests. Questioned Costs $218,000 Recommendation We recommend that management enhance their controls over the review of their third-party insurance payment calculation to ensure the accuracy of the information provided to FEMA. Additionally, we understand management continues to have conversations with MEMA over different aspects of the third-party insurance payment calculation and we recommend through those discussions the System, along with MEMA and FEMA, as applicable, determine whether there are any amounts that should be reimbursed to FEMA. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.

Corrective Action Plan

2022-002 Insurance payments not fully deducted from FEMA funding Cluster: Not applicable Grantor: U.S. Department of Homeland Security Award Names: COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Award Year: January 20, 2020 ? July 1, 2022 Award Number: 4496DR-MA Assistance Listing Numbers: 97.036 Pass through entity: Massachusetts Emergency Management Agency (?MEMA?) Management?s Views and Corrective Action Plan Management?s View Management agrees with the Auditors? assessment of the System?s internal controls over compliance specifically related to the estimated third-party insurance deduction calculated for COVID-19 PCR tests administered between March 1, 2020 and June 30, 2021 included with one of the eight FEMA projects obligated during fiscal year 2022. The System calculated the third-party insurance deduction by developing an average third-party insurance payment rate per test. A formula error was present in this calculation. Corrective Action Plan Management will create a formal review process whereby third-party insurance deductions will be verified by an individual other than the preparer as part of the FEMA project workbook submission procedures. As of the date of this report, Management has informed MEMA of the error and discussed with MEMA an alternate methodology to calculate the third-party payment deduction. As a result of the alternate methodology identified, the amount owed back to FEMA in the form of an under-estimated medical payment deduction will be substantially less than the $218,000 in questioned costs noted. These monies will be refunded to MEMA as soon as all parties agree on the amount owed. Responsible Official: Michael Knoll, Executive Director, Financial Planning & Analysis Expected Completion Date: September 30, 2023

Categories

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $37.00M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $8.95M
21.019 Coronavirus Relief Fund $1.01M
32.006 Covid-19 Telehealth Program $996,406
93.461 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $468,425
21.027 Coronavirus State and Local Fiscal Recovery Funds $320,000