Finding 22089 (2022-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-06-28

AI Summary

  • Core Issue: The Corporation inaccurately reported health care expenses in the PRF submissions, overstating costs by over $9 million across two periods.
  • Impacted Requirements: Reporting did not comply with HHS guidelines, which specify that only current period expenses should be reported.
  • Recommended Follow-Up: Enhance reporting controls with additional review levels to ensure compliance with HHS guidelines for future submissions.

Finding Text

ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19: Provider Relief Fund and American Rescue Plan Rural Distribution (PRF) Federal Award Identification Number and Year - N/A, 2022 Pass-through Entity N/A, Direct funded Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund Distributions and American Rescue Plan Rural Distributions Post Payment Notice of Reporting Requirements dated October 27, 2022, published by the U.S. Department of Health and Human Services (HHS), allowable expenses paid with general and targeted PRF distributions may be reported as a use of PRF funds, provided that the expenses have not been reimbursed by another source. Additionally, per the Health Resources and Services Administration (HRSA) PRF Reporting Portal user guide, "the reporting entity must report the use of these payments by indicating the quarterly expenses reimbursed for these payments" once these expenses have been entered, and the portal will automatically calculate an unreimbursed expense amount for any PRF expenses entered that exceed PRF funding received. As a result of this calculation, the directions from HRSA require users to only input expenses related to the current period's payments in the current portal submission. Condition - The Corporation's controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of expenses. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information Context - The reporting submission for health care expenses did not follow the guidelines published by HHS. The Corporation's Period 2 and Period 3 portal submissions overstated expenses by $3,032,735 and $6,185,506, respectively, that were included within previously submitted portal submission. These expenses should not have been re entered in the Period 2 and Period 3 submissions. Due to the Corporation having excess allowable health care expenses and lost revenue reported in the portal submissions that could have been utilized to support the retention of the PRF funds, the Corporation still would have qualified to recognize all PRF payments received in Period 2 and Period 3. Cause and Effect - The review process surrounding the expenses reported was not sufficient to ensure that the expenses were accurately reported. As a result, the report submitted was inaccurate, but the schedule of expenditure of federal awards was not impacted. Recommendation - We recommend the Corporation enhance controls, including additional levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Corporation accepts the finding and will implement additional layers of review regarding expense submission to ensure the reports are submitted within the established guidelines. As stated above, the lost revenue from the COVID-19 pandemic more than offsets this finding, and there are no resulting PRF recognition issues.

Corrective Action Plan

Finding Number: 2022-001 Condition: The Corporation?s controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of expenses. Planned Corrective Action: The Corporate Controller will request all Portal Submission Documents from the subsidiaries after their completion. The Corporate Controller and VP of Reimbursement will reconcile the portal submission documents completed by the subsidiaries to the documentation provided by our FEMA claims partner to ensure accuracy. If any discrepancies are noted, we will notify the subsidiary CFOs of the irregularities and request they edit the submission with the correct information. Once completed by the subsidiary CFOs, the updated submission documents will be re-reviewed to ensure accuracy. This process will continue until the portal submission documents are accurate. Contact person responsible for corrective action: Brian Balutanski, Vice President and Corporate Controller. Anticipated Completion Date: 06/01/2023

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Reporting

Other Findings in this Audit

  • 598531 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan Rural Distribution $59.31M
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $16.75M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.95M
93.697 Covid-19 Testing and Mitigation for Rural Health Clinics $1.70M
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $866,445
93.155 Rural Health Research Centers $257,853
93.247 Advanced Nursing Education Grant Program $105,352
93.110 Maternal and Child Health Federal Consolidated Programs $99,423
93.178 Nursing Workforce Diversity $29,240
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $18,525
93.301 Small Rural Hospital Improvement Grant Program $11,679
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $6,512