Finding 38319 (2022-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-06-28
Audit: 30701
Organization: Brown Dermatology, Inc. (RI)

AI Summary

  • Core Issue: The Organization failed to report PRF Period two results by the March 31, 2022 deadline due to a clerical error and internal miscommunication.
  • Impacted Requirements: Non-compliance with the PRF reporting requirements jeopardizes the Organization's standing with the U.S. Department of Health and Human Services.
  • Recommended Follow-Up: Management should revise reporting procedures and contact the award administrator to submit the overdue Period two results.

Finding Text

U.S. Department of Health and Human Services ? Direct Funding Provider Relief Fund (PRF) and American Rescue Plan Rural Distribution Program Assistance Listing No. 93.498 ? Year ended September 30, 2022 2022-001 - Significant Deficiency in Internal Control and Compliance - Reporting Criteria: All recipients of Provider Relief Fund (PRF) payments must comply with the reporting requirements described in the PRF terms and conditions and specified in the directions issued by the U.S. Department of Health and Human Services (HHS). Recipients of PRF Period two funding are required to report on the Provider Relief Reporting Portal no later than March 31, 2022. Condition/Context: The Organization missed the reporting time frame to report PRF Period two results on the Provider Relief Reporting Portal and therefore has not reported results of Period two in accordance with the terms and conditions of the award. Cause: Internal miscommunication / error. A clerical error occurred when a junior member of the finance team accidently changed the payment receipt date to coincide with the date funds were applied to revenue, a Period three date. The Organization became aware of the missed Period two submission upon attempting a Period three submission when they were denied because the Organization had no Period three receipts. Also, there was a Lack of receipt of reporting communications from HRSA. Per the HRSA web site under the section ?Process for Submitting a Late Report Request? it was noted in item 1, ?All providers who are considered non-compliant will be notified by HRSA after the conclusion of the Reporting Period and will be given details on how to submit a ?Request to Report Late Due to Extenuating Circumstances.? As of June 28, 2023, the Organization has not been notified. Effect: The Organization is not in compliance with the reporting requirements of Period two PRF reporting. Recommendation: We recommend that management review and update, as needed, their procedure for completion and filing of third-party reporting to ensure reporting is completed on a timely basis. In addition, we recommend that management contact its award administrator to appropriately report the results of the Organization?s Period two PRF funds. Views of Responsible Officials and Planned Corrective Actions: Management of Brown Dermatology, Inc. agrees with the finding and its corrective action is outlined in the accompanying Corrective Action Plan. Questioned Cost: None reported.

Corrective Action Plan

Awarding Agency: U.S. Department of Health and Human Services ? Direct Funding Assistance Listing No.: 93.498 - Provider Relief Fund and American Rescue Plan Rural Distribution Program Audit Period: Year Ended September 30, 2022 Finding # 2022-001 Significant Deficiency in Internal Control and Compliance - Reporting Condition: The Organization missed the reporting time frame to report PRF Period two results on the Provider Relief Reporting Portal and therefore has not reported results of Period two in accordance with the terms and conditions of the award. Cause: Internal miscommunication / error. A clerical error occurred when a junior member of the finance team accidently changed the payment receipt date to coincide with the date funds were applied to revenue, a Period three date. The Organization became aware of the missed Period two submission upon attempting a Period three submission when they were denied because the Organization had no Period three receipts. Also, there was a Lack of receipt of reporting communications from HRSA. Per the HRSA web site under the section ?Process for Submitting a Late Report Request? it was noted in item 1, ?All providers who are considered non-compliant will be notified by HRSA after the conclusion of the Reporting Period and will be given details on how to submit a ?Request to Report Late Due to Extenuating Circumstances.? As of June 28, 2023, the Organization has not been notified. Corrective Action Plan: We agree with the finding and have updated our procedures to prevent future delays in reporting. When the late filing became evident, we reviewed the HRSA website under ?Request to Report Due to Extenuating Circumstances? and noted the Period two portal remained open to accept late reporting requests until May 18, 2022, which was months before we had identified the problem. Once we identified the late filing, we pro-actively communicated on several occasions with the HSRA office and was told that since the portal period had closed, they had no means to accept the report. The HSRA office verbally communicated that we should be notified by the HSRA of non- compliance and when we received notification of non-compliance, they would provide guidance on how to submit our report. Time went by and after additional communications with the HRSA office in which we enlisted the assistance of our congressional delegates, no further was action. As of June 28, 2023, we have not been contacted by the HRSA Office. Our plan is to submit our report for Period two once we are provided direction to do so. Name of Contact Person Responsible for Corrective Action: Judith Lancellotta, CPA, Director of Finance Anticipated Completion Date: Immediately

Categories

Reporting Significant Deficiency

Other Findings in this Audit

  • 614761 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $788,932