Finding Text
Identification of the federal program: Federal Grantor: U.S. Department of Health and Human Services Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: January 1, 2020 ? December 31, 2022 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 requires the following: ? The recipient certified that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. ? The recipient shall submit reports as the secretary of Health and Human Services (HHS) determines are needed to ensure compliance with conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: Per discussion with management, the Company has processes and internal controls over compliance with the terms and conditions of the award; however, management did not retain documentation evidencing the performance of these controls. Cause: Due to turnover, management did not retain documentation evidencing the performance of controls. Effect or potential effect: The Hospital did not consistently retain documentation to evidence the performance of internal controls over compliance with the terms and conditions of the award. Questioned Costs: None. Context: During our testing over the PRF program, we observed that management did not retain evidence of controls surrounding compliance with terms and conditions of the award. Total federal expenditures for Assistance Listing No. 93.498 totaled $1,360,603 for the year ended December 31, 2022. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should refine its process and retain documentation evidencing that management reviewed compliance with the terms and conditions of the award. View of Responsible Officials: The Hospital agrees with the finding and will implement procedures to ensure control documentation is retained.