Finding Text
ALN Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), COVID 19 Provider Relief Fund 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 General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, recipients may choose to apply PRF payments towards lost revenues using one of three options, up to the amount: Option i: of the difference between actual patient care revenues; Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues; or Option iii: calculated by any reasonable methodology of estimating revenues. Condition - The Hospital's controls in place for reporting submissions did not identify that Post Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 1 reporting submission for lost revenue did not follow the acceptable options provided by the HHS. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Refer to context below for additional information. Context - The Hospital was required to submit one portal submision, which contained lost revenue amounts for six total quarters (four for calendar year 2020 and two for calendar year 2021). The Period 1 reporting submission for lost revenue did not follow the acceptable options provided by the HHS, as noted in the criteria, above. The Hospital had reported to HHS that they used option ii to calculate their their lost revenue included in their portal submissions. However, the budgeted amounts for patient care revenue relating to the second quarter in calendar year 2021 were not approved prior to March 27, 2020, therefore, option ii was not allowable. The Hospital should have selected option iii in its portal submissions. Finally, by not selecting option iii in the portal submission, the Hospital omitted required information related to the reason for selecting option iii in their submissions. Cause and Effect - Appropriate review of the reporting submissions was not completed to ensure the reports followed required guidelines. As a result, the Hospital selected an incorrect methodology option (option ii) for reporting lost revenues. Additionally, because the Hospital used an incorrect option, they did not provide additional information to HHS required under the correct option (option iii). The additional information included an explanation for the reason the Hospital used option iii for reporting lost revenue. Recommendation - We recommend that the Hospital implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - The Hospital will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue methodology is used in future reporting periods. The third submission to HRSA (9/30/2022) corrected this oversight and used the eligible budget values for all previous submissions (i.e., this first one) and future submissions.