Finding 20674 (2022-003)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2023-03-29
Audit: 23696
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Surgery Center failed to document PRF expenses as related to COVID-19, leading to questioned costs of $681,390.
  • Impacted Requirements: Expenses for salaries, insurance, and rent were not properly attributed to coronavirus or verified as eligible for reimbursement.
  • Recommended Follow-Up: Update policies and procedures to ensure compliance with federal grant reporting and allowable activities for future expenditures.

Finding Text

COVID-19 Provider Relief Fund and American Rescue (ARP) Rural Distribution CFDA No. 93.498 U.S. Department of Health and Human Services Criteria or Specific Requirement ? 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) Condition ? Butler Ambulatory Surgery Center, LLC (the ?Surgery Center?) is a joint venture that operates an ambulatory surgery center. The System maintains a 51 percent ownership share in the Surgery Center. The Surgery Center was required to file a Period 2 Provider Relief Fund (PRF) report during the year; however, did not maintain adequate documentation to support the other PRF expenses were attributable to coronavirus and/or had not been or were not eligible to be reimbursed by other sources. Questioned Costs ? $681,390 Context ? The Surgery Center utilized PRF payments received on salaries and employee benefits without identifying portions of employee?s time directly attributed to coronavirus. The Surgery Center also utilized PRF payments received on annual insurance premiums, without identifying the portion of the increased premiums attributable to coronavirus. In addition, the Surgery Center utilized PRF payments received on their entire monthly building rent costs for the clinic, without identifying the portion of expense attributable to coronavirus. The Surgery Center was unable to provide adequate documentation to support the other PRF expenses had not been or were not eligible to be reimbursed by other sources. Effect ? The Surgery Center utilized PRF payments received on expenses that were not documented as attributable to coronavirus, were potentially reimbursed by other sources, and/or were not allowable in accordance with other guidance issued by HHS. Cause ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution is a new program with complex and evolving regulations and compliance requirements. Internal controls were not in place to ensure the Surgery Center correctly applied the guidance. Identification as a repeat finding ? Not a repeat finding Recommendation ? Policies and procedures over allowable activities and federal grant reporting should be modified to ensure expenditures charged to grants are for activities allowed and federal grant reports are prepared using complete and accurate information.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions ? Management acknowledges errors were made by contracted vendor for a subsidiary provider reporting submission. Management?s corrective action plan includes establishing appropriate review and approval process whereby the parent organization is reviewing reporting submission of subsidiary organizations including those prepared by third-party vendors. In addition, future reporting submissions will be prepared with oversight by the parent organization to ensure corrections are made retroactive to the covered period of this audit.

Categories

Questioned Costs Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 20675 2022-004
    Significant Deficiency
  • 597116 2022-003
    Material Weakness
  • 597117 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $5.94M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.27M
10.766 Community Facilities Loans and Grants $1.00M
93.697 Covid-19 Testing for Rural Health Clinics $149,461
93.461 Covid-19 Testing for the Uninsured $133,298
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $49,529