Finding 28333 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-06-08

AI Summary

  • Core Issue: The Corporation inaccurately reported health care expenses, overstating them by $10,329,866 in the Period 3 submission.
  • Impacted Requirements: Reporting did not comply with HHS guidelines, specifically regarding the input of expenses related to current payments.
  • Recommended Follow-Up: Implement additional review controls to ensure compliance with HHS reporting guidelines and prevent future inaccuracies.

Finding Text

ALN, 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 Significant deficiency 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 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 3 portal submission overstated expenses by $10,329,866 that were included within the Period 1 portal submission. These expenses should not have been re entered in the Period 3 submission. Due to the Corporation having additional health care expenses and lost revenue 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 3. Cause and Effect Appropriate review of the expenses reported was not completed to ensure that the expenses were properly 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 implement controls, including 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: 2022-01 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: Reviews of the PRF allowable expenditures and stats are reviewed by the Chief Financial Officer, as prepared by the Accounting Manager and Reimbursement Manager. The PRF portal Excel template is populated by the Reimbursement Manager and manually keyed into the portal. The Chief Financial Officer reviews the Excel template, tracing back to source documents, and reviews the portal print out for consistency given manual keying. The finding was due to a misunderstanding of the portal not wanting cumulative data from prior submissions with having prior period fields still open for input (like the stat reporting section). This was found by management with the final Phase 4 PRF submission where expenses were not allowed to be input due to reaching the total PRF funds, but expenses tracked never fully reached that level. Management made a request to HRSA to reopen Phase 3 reporting to correct the error and was told they would not reopen for correction (see attached file). Management has and will continue to follow up if a correction can be made; however, per discussion with the agent, they likely would not given PHC?s lost revenues more than cover the error in reporting. Management will continue to thoroughly review this and any other grant reporting submissions and ensure a full understanding of such requirements as well as check totals provided by the reporting mechanism. Related to the PRF grant compliance, final Phase 4 filing was completed and no further compliance or reporting needs remain in the future for PRF at this time. Contact person responsible for corrective action: Andy Gutierrez, Chief Financial Officer Anticipated Completion Date: 03/31/2023 coinciding with PHC?s final Phase 4 PRF submission

Categories

Allowable Costs / Cost Principles Reporting Significant Deficiency

Other Findings in this Audit

  • 604775 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan Rural Distribution $18.68M
93.461 Covid-19 Testing for the Uninsured $403,617
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $150,850
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $103,202
93.470 Alzheimer's Disease Program Initiative (adpi) $90,276
93.268 Immunization Cooperative Agreements $89,246