Finding 22152 (2022-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-27

AI Summary

  • Core Issue: Management lacked effective internal controls to ensure accurate reporting of lost revenue calculations for federal funds, leading to potential errors in submissions.
  • Impacted Requirements: This finding violates Section 200.303 of the Uniform Guidance, which mandates maintaining internal controls that ensure compliance with federal award terms.
  • Recommended Follow-Up: Management should enhance internal controls, maintain supporting documentation, and conduct thorough reviews to prevent future misstatements and ensure compliance.

Finding Text

Finding 2022-001 ? Reporting Identification of the federal program: Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: Assistance Listing 93.498, Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Federal Award Numbers: N/A Federal Award Period of Performance: April 10, 2020 ? December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) 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. These internal controls 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 (COSO).? The terms and conditions of the award require the recipient to submit reports to the secretary of HHS for each reporting period to ensure compliance with conditions that are imposed on the payment, and such report shall be in such form, with such content that is complete and accurate, as specified by the secretary of HHS in program instructions directed to all recipients. Condition: Management did not have sufficiently designed internal controls to identify material misstatements and evidence review of the supporting documentation used in the lost revenue calculation and the data submitted into the HHS portal for Period 2. Section III ? Federal Award Findings and Questioned Costs (continued) Finding 2022-001 ? Reporting (continued) Cause: Management represented they performed a review and approved the lost revenue calculation and HHS portal submission; however, supporting documentation to evidence that the internal controls were appropriately designed and operating effectively was not maintained. Effect or potential effect: A lack of sufficiently designed internal controls over the review of the lost revenue calculations could lead to errors in the calculations and/or improper conclusions regarding the retention of Provider Relief Funds or errors in the data submitted to HRSA in the HHS portal. Questioned costs: None. Context: There was a total of six PRF lost revenue calculations and HHS portal submissions for the year ended June 30, 2022, all of which were submitted during Period 2. CFNI had no funding during Period 3 and, therefore, had no reporting submissions. We tested 5 PRF lost revenue calculations and HHS portal submissions for the year ended June 30, 2022, making up 94.68% of the FY22 PRF total per the SEFA. One entity, Community Village, Inc. (CVI), understated the Q3 2021 lost revenue within the Period 2 report submission, as there was $354,213 of calculated lost revenue for the quarter per the lost revenue calculation, but the amount that was reported was $0. Total PRF lost revenue on the SEFA is $20,240,401 for the year ended June 30, 2022. Identification as a repeat finding, if applicable: Yes, repeat of finding 2021-001

Corrective Action Plan

Corrective Action Plan Finding 2022-001 ? Reporting Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: Assistance Listing 93.498, Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Federal Award Numbers: N/A Federal Award Period of Performance: July 1, 2020 ? December 31, 2020 A material weakness was issued related to reporting for the Provider Relief Funds (PRF) that represented the major program subject to the Uniform Guidance (UG) audit. This included a compliance finding with no questioned costs. Community Foundation of Northwest Indiana, Inc. and Subsidiaries (CFNI) did not maintain written documentation of the detailed review and approval process of the underlying lost revenue calculations or the approval and sign-off process for the portal submission. CFNI Finance has developed a policy and checklist to maintain written documentation of the review and approval process required under current audit standards to improve internal controls going forward. Due to the timing of the prior year UG audit, the implementation of the new policy could not impact the current UG audit, resulting in the same finding. This has been corrected for future audits with the policy being effective October 2022. In the compliance finding, management failed to catch a change in formula to a large excel file returned from an external resource. This resulted in underreporting lost revenues for one entity. The finding affirms the need for an official policy identified in the reporting deficiency, which CFNI has fully corrected, and management will improve the review process and communication over changes to files sent and received from both internal and external resources. CFNI will correct the reporting error in the next reporting submission for period 4. Responsible Official: Pamela Pokropinski, Director Accounting & Financial Systems Status of finding: Fully corrected.

Categories

Reporting Period of Performance Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 598594 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $20.24M
93.461 Covid-19 Claims Reimbursement to Health Care Providers and Facilities for Testing and Treatment of the Uninsured Program $678,299
32.006 Covid-19 Telehealth Program $434,162
97.008 Non-Profit Security Program $8,436
93.RD Convalescent Plasma Expanded Access Protocol (eap) - Clinical Trial $1,600