FAC Explorer

Finding 382287 (2023-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-20
Audit: 295994
Organization: Ascension Health Alliance D/b/a Ascension (MO)
Auditor: Ernst & Young

AI Summary

  • Core Issue: Ascension Living lacks proper internal controls for reviewing new vendors for suspension and debarment, risking the use of ineligible contractors.
  • Impacted Requirements: Compliance with Section 200.303 of the Uniform Guidance regarding effective internal controls over federal awards is not met.
  • Recommended Follow-Up: Formalize vendor review processes and ensure data transfer integrity to third-party vendors, including retaining supporting documentation.

Finding Text

Information of the federal program: Federal Grantor: United States Department of the Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: State of Illinois Department of Healthcare and Family Services Ascension Ministry Market: Illinois Pass-Through Award Number: ARPA230159, ARPA230263, ARPA230050 Pass-Through Award Period: 05/01/2022-06/30/2023 Pass-Through Grantor: State of Illinois Department of Public Health Ascension Ministry Market: Illinois Pass-Through Award Numbers: 38080717K, 38080718K Pass-Through Award Period: 07/01/2022-06/30/2023 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).” Condition: Internal controls over suspension and debarment related to new vendor set up were not in place for Ascension Living. Specifically, documentation was not retained evidencing the review of new vendors for suspension and debarment prior to adding them into MatrixCare, Ascension Living’s current vendor management platform.The System has an internal control to review the accuracy of the vendor files transferred from the System’s vendor management system to ProviderTrust, the System’s third-party vendor engaged to perform its suspension and debarment review. The review of the completeness and accuracy of the data transferred to ProviderTrust was only performed for three of the twelve months during fiscal year 2023. The System has several IT applications that contain source vendor listings. Internal controls were not in place over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment (Ascension Living, Illinois). Cause: Management at Ascension Living did not have a requirement to retain the supporting documentation evidencing the review of new vendors for suspension and debarment. The System’s internal control over the review of the accuracy of the data transfer to ProviderTrust was not designed to review the completeness and accuracy of the data each time it is transferred to the third-party vendor. Internal controls were not in place at Ascension Living over the accuracy and completeness of the vendor listings from MatrixCare used to monitor the suspension and debarment. Effect or potential effect: New vendors may be used that are suspended or debarred. Suspension and debarment vendor files provided to the third-party vendor may not be accurate or complete. The data from MatrixCare transferred to the third-party vendor for suspension and debarment may not be complete and accurate. Federal funds may be used to pay a contractor that is suspended or debarred. Questioned costs: None. Context: For Assistance Listing No. 21.027, procurement expenditures subject to suspension and debarment review for Ascension Living, Illinois, totaled $1,369,015, which represents approximately 29% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Total federal portion of procurement expenditures subject to suspension and debarment review was $2,279,109, which represents approximately 47% of total federal expenditures of $4,798,357 reported in the SEFA for the year ended June 30, 2023. Identification as a repeat finding, if applicable: The finding is not a repeat finding from the prior year. Recommendation: Ascension Living should formalize the review and approval process of new vendors for suspension and debarment by authorized individuals that would include retention of evidence of the review, including documentation of the elements of the review process validated by the reviewer. The System should develop internal controls to ensure the integrity of data transfer to the third-party vendor is validated each time the data is transferred. Views of responsible officials: Ascension Living will provide education to their associates performing initial suspension and debarment screening as part of onboarding control activities to retain evidence of their review and the supporting documentation. Management will reassess controls over the data transfer application used to send the vendor data file to the third-party vendor, ProviderTrust. The System will explore implementing compensating controls for MatrixCare. The application is anticipated to be sunset in early 2025, when the process is migrated to Oracle Cloud and the established ProviderTrust processes.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 382278 2023-001
    Material Weakness
  • 382279 2023-001
    Material Weakness
  • 382280 2023-001
    Material Weakness
  • 382281 2023-001
    Material Weakness
  • 382282 2023-002
    Material Weakness
  • 382283 2023-004
    Material Weakness
  • 382284 2023-002
    Material Weakness
  • 382285 2023-003
    Material Weakness
  • 382286 2023-004
    Material Weakness
  • 382288 2023-004
    Material Weakness
  • 382289 2023-001
    Material Weakness
  • 382290 2023-001
    Material Weakness
  • 958720 2023-001
    Material Weakness
  • 958721 2023-001
    Material Weakness
  • 958722 2023-001
    Material Weakness
  • 958723 2023-001
    Material Weakness
  • 958724 2023-002
    Material Weakness
  • 958725 2023-004
    Material Weakness
  • 958726 2023-002
    Material Weakness
  • 958727 2023-003
    Material Weakness
  • 958728 2023-004
    Material Weakness
  • 958729 2023-003
    Material Weakness
  • 958730 2023-004
    Material Weakness
  • 958731 2023-001
    Material Weakness
  • 958732 2023-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $284.60M
93.697 Covid-19 Testing and Mitigation for Rural Health Clinics $2.87M
93.600 Head Start $1.27M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $1.00M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $948,803
93.516 Public Health Training Centers Program $689,090
93.461 Covid-19 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $639,133
93.575 Covid-19 Child Care and Development Block Grant $613,433
14.241 Housing Opportunities for Persons with Aids $538,314
93.958 Block Grants for Community Mental Health Services $533,719
93.268 Covid-19 Immunization Cooperative Agreements $506,050
84.181 Special Education-Grants for Infants and Families $461,682
17.720 Disability Employment Policy Development $460,051
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $430,275
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges $391,333
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $375,340
93.650 Accountable Health Communities $350,623
93.788 Opioid Str $337,507
16.575 Crime Victim Assistance $329,541
14.195 Section 8 Housing Assistance Payments Program $237,313
97.039 Hazard Mitigation Grant $232,713
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $228,561
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $204,574
10.331 Covid-19 Food Insecurity Nutrition Incentive Grants Program $187,500
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $181,658
20.600 State and Community Highway Safety $177,988
93.301 Covid-19 Small Rural Hospital Improvement Grant Program $161,668
14.267 Continuum of Care Program $144,866
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $139,604
93.RD Rapid Assessment of Acute Illness and Injury to Enhance the U.s. Response to Public Health Emergencies $125,023
93.917 Hiv Care Formula Grants $122,731
93.732 Mental and Behavioral Health Education and Training Grants $115,688
93.155 Covid-19 Rural Health Research Centers $111,508
93.889 Covid-19 National Bioterrorism Hospital Preparedness Program $100,605
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B $96,911
16.710 Public Safety Partnership and Community Policing Grants $89,084
16.320 Services for Trafficking Victims $76,464
93.558 Temporary Assistance for Needy Families $69,093
93.667 Social Services Block Grant $61,113
14.191 Multifamily Housing Service Coordinators $59,261
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $56,587
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $55,918
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $55,643
16.585 Treatment Court Discretionary Grant Program $53,383
12.420 Military Medical Research and Development $46,422
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $32,422
10.558 Child and Adult Care Food Program $27,094
93.247 Advanced Nursing Education Grant Program $25,494
93.914 Hiv Emergency Relief Project Grants $25,000
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $20,000
10.555 National School Lunch Program $19,984
93.241 State Rural Hospital Flexibility Program $19,930
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $17,748
93.865 Child Health and Human Development Extramural Research $17,745
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $17,648
93.994 Maternal and Child Health Services Block Grant to the States $13,000
93.310 Trans-Nih Research Support $12,000
93.301 Small Rural Hospital Improvement Grant Program $10,825
93.350 National Center for Advancing Translational Sciences $10,000
97.240 Emergency Food and Shelter National Board Program $10,000
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $5,850
93.837 Cardiovascular Diseases Research $4,000
93.395 Cancer Treatment Research $2,600
10.545 Covid-19 Farmers’ Market Supplemental Nutrition Assistance Program Support Grants $2,532
93.394 Cancer Detection and Diagnosis Research $1,750
93.556 Marylee Allen Promoting Safe and Stable Families Program $1,569
93.361 Nursing Research $1,326
93.399 Cancer Control $944
93.669 Child Abuse and Neglect State Grants $597
93.387 National and State Tobacco Control Program $80