Finding 1240436 (2025-002)

Material Weakness Repeat Finding
Requirement
ABN
Questioned Costs
-
Year
2025
Accepted
2026-10-14
Audit: 414944
Organization: Asante Health System (OR)
Auditor: KPMG

AI Summary

  • Core Issue: Duplicate expenditures totaling $2,636,044 were submitted for reimbursement under the COVID-19 Disaster Grants program, indicating a lack of adequate controls.
  • Impacted Requirements: Compliance with 2 CFR 200 regarding allowable costs and proper accounting for federal awards was not met, leading to potential material non-compliance.
  • Recommended Follow-Up: Strengthen internal controls and review processes to ensure all expenditures are accurately tracked and certified before submission for reimbursement.

Finding Text

Federal Assistance Listing Number: 97.036 Program: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Agency Name: US Department of Health and Human Services Federal Award Number:4499DRORP 00008961 Federal Award Year: 2025 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Special Tests and Provisions Criteria: Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E, Section 200.403(a) states that costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F, Section 200.514(d), auditors must test compliance with Special Tests and Provisions. Under the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) 44 CFR 206.205, the recipient shall make an accounting to the Regional Administrator of eligible costs for each approved large project. In submitting the accounting the recipient shall certify that reported costs were incurred in the performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, and that payments for that project have been made in accordance with 2 CFR 200.305. Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the non- Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: In six of 40 sample items selected for testwork over activities allowed or unallowed and allowable costs/cost principles related to the program, $469,054 in expenditures out of a total of $1,368,522 expenditures (or 34%) were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) but were related to the same invoices and therefore were duplicate expenditures. Upon further investigation, management identified that a total of $2,636,044 expenditures out of a total of $14,470,349 expenditures related to the program were duplicate expenditures. Further, management’s review that was performed over the underlying program details was not designed at a sufficient level of precision that enabled the identification of the duplication errors. Further, in management’s review for the completed project certification for one of two projects for the program these duplication errors were not identified. Cause: In discussing these conditions with management, they stated the Entity did not have adequate controls in place that were designed appropriately to ensure that all the expenditures submitted for reimbursement and certified to FEMA under the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program represented allowable costs. Effect: Expenditures could be reimbursed by the program that were not allowable or certified incorrectly, resulting in material non-compliance with program requirements. Questioned Costs: Known questioned costs of $2,636,044. Statistical Sample: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding:This finding is not a repeat finding. Recommendation:We recommend that management strengthen processes and controls in place to ensure expenditures submitted for reimbursement and certified under the program are appropriately reviewed prior to submission to ensure they represent allowable costs. Views of Responsible Officials: Management agrees with the finding and acknowledges that duplicate expenditures were submitted for reimbursement under the FEMA program. The error resulted from insufficient controls over the tracking, reconciliation, and review of specific expenditures included in reimbursement requests, which allowed certain invoices to be claimed more than once. Upon identification of the issue, management conducted a comprehensive review of all reimbursement requests submitted under the program and identified the full population of duplicate expenditures. Management is committed to maintaining full compliance with federal award requirements and has implemented corrective actions to strengthen reimbursement controls, including enhanced expenditure tracking, independent secondary review procedures, reconciliation of submitted costs to prior claims, and updated policies and staff training. Management does not believe the finding resulted from an intentional misuse of federal funds, but rather from a limited lapse in internal controls over the reimbursement process. Management is working with FEMA, as appropriate, to resolve the duplicate claims.

Corrective Action Plan

Asante Health System Corrective Action Plan for FY25 Single Audit Fiscal year end: 09/30/2025 Audit period: 10/01/2024-09/30/2025 Finding 2025-002 Federal Program: FEMA funding is federal financial aid from the Federal Emergency Management Agency’s Disaster Relief Fund (DRF), providing money for communities to recover from disasters, rebuilding infrastructure, mitigating future risks, and covering essential needs. Duplicate expenditures submitted for FEMA reimbursement resulting in unallowable costs being claimed under the program. Statement of Condition: In six of 40 sample items selected for testwork over activities allowed or unallowed and allowable costs/cost principles related to the program, $469,054 in expenditures out of a total of $1,368,522 expenditures (or 34%) were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) but were related to the same invoices and therefore were duplicate expenditures. Upon further investigation, management identified that a total of $2,636,044 expenditures out of a total of $14,470,349 expenditures related to the program were duplicate expenditures. Further, management’s review that was performed over the underlying program details was not designed at a sufficient level of precision that enabled the identification of the duplication errors. Further, in management’s review for the completed project certification for one of two projects for the program these duplication errors were not identified. Actions Taken and Status: To address this deficiency, the organization has implemented the following corrective actions: 1. Recovery and Adjustment of Duplicate Claims o A complete review of all FEMA reimbursement submissions was performed to identify duplicate expenditures. o Management will work with FEMA to adjust previous reimbursement requests and return any funds received for duplicate expenditures, as required. 2. Enhanced Reconciliation Controls o A detailed reimbursement tracking log has been implemented to identify each invoice: payment date, reimbursement request number, and reimbursement status. o All expenditures submitted for reimbursement will be reconciled against prior submissions before inclusion in a reimbursement request. 3. Training o Finance personnel responsible for federal grant administration and reimbursement submissions have received training on Uniform Guidance requirements, allowable costs, and reimbursement documentation controls. Corrective action training has been completed as of 9/30/2026. Responsible Contact Person: Name: Heather Rowenhorst Title: Chief Financial Officer Department: Administration Phone/Email: 541-789-5098 / Heather.Rowenhorst@asante.org

Categories

Allowable Costs / Cost Principles Special Tests & Provisions

Programs in Audit

ALN Program Name Expenditures
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $14.47M
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $30,600
93.301 SMALL RURAL HOSPITAL IMPROVEMENT GRANT PROGRAM $2,901