Finding Text
Finding Number: 2022-001 Finding Type: Compliance - Reporting Information on the Federal Program: Program Name: COVID-19 Provider Relief Fund (AL 93.498) Award Period: January 1, 2020 - June 30, 2021 Award Number: n/a Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Criteria: Specific criteria were established by HHS with respect to allowable costs and reporting requirements for the Provider Relief Fund (PRF), including that the PRF shall reimburse the recipient only for healthcare related expenses or lost revenues that are attributable to COVID-19. Providers have three options for calculating lost revenues. HRSA provided additional guidance related to the options in their Lost Revenues Guide released in August 2021 as summarized below: Option 1) Actuals - difference between 2020/2021 actual patient care revenues and 2019 actual patient care revenues. Option 2) Budgets - difference between 2020/2021 actual patient care revenues and 2020/2021 budgeted patient care revenues. The budgets must have been approved prior to March 27, 2020 and cover the entire period of availability (January 1, 2020 through June 30, 2021). Option 3) Any reasonable method of estimating revenues. This option provides significant flexibility for providers because it allows providers to account for their unique circumstances, particularly where Options 1 or 2 may not appropriately capture their situation. Condition: For the Period 1 PRF Reporting Portal submission filed in September 2021, the Organization selected Option 2 to report the lost revenues. However, as a entity with a March 31 fiscal year end, the Organization's fiscal year 2020 and 2021 board approved budgets, which were approved prior to March 27, 2020, did not cover the second quarter in 2021 (April 1, 2021 to June 30, 2021) which was part of the required reporting. As a result, the Organization should have selected Option 3 to report lost revenues. This was determined to be a clerical error in reporting the methodology used to report lost revenue for Period 1. Cause: The Period 1 PRF Reporting Portal submission was completed before the initial deadline of September 30, 2021. During the period in which management was completing lost revenue calculations and preparing the submission, HRSA was continuing to issue guidance via frequently asked questions and a lost revenues guide. As a result of both occurring simultaneously, management was not able to fully review and incorporate the updated guidance when making the Period 1 PRF Reporting Portal submission. As a result, the appropriate option for calculating lost revenue was not selected. Management's procedures included a review process which was performed before submission, but the procedures did not detect and correct the error prior to submission. Effect: The Organization's reporting in the PRF Reporting Portal inaccurately described the method used to calculate lost revenue, but did not impact the Organization's lost revenue calculations or the accuracy of the total revenue numbers reported for Period 1 PRF Reporting Portal submission. Questioned Costs: None Repeat Finding: No Recommendation: We recommend management continue to perform internal review procedures as well as review the most recent updated guidance prior to completing subsequent portal submissions. Additionally, we recommend management communicate the error noted in the submission to HRSA and request advice for how to correct this error. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and will implement additional review procedures of relevant guidance prior to subsequent PRF Reporting Portal submissions.