Finding 389331 (2023-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-29

AI Summary

  • Core Issue: The Agency failed to follow HHS guidelines for lost revenue calculations in its Provider Relief Fund submissions, using an incorrect methodology.
  • Impacted Requirements: Reporting submissions for Period 2 and Period 4 did not adhere to acceptable options outlined by HHS, specifically using option ii when option iii was required.
  • Recommended Follow-Up: Implement stronger controls and review processes to ensure compliance with HHS reporting guidelines in future submissions.

Finding Text

Assistance Listing, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services (HHS), Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Federal Award Identification Number and Year - N/A 2022 Pass through Entity - N/A Finding Type - Material weakness 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 October 27, 2022, recipients may choose to apply PRF payments toward lost revenue 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 Agency's controls in place for reporting submissions did not identify Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 4 reporting submission for lost revenue did not follow the acceptable options outlined by HHS. Additionally, the Period 2 reporting submission, completed in the previous year, did not follow the acceptable options. Questioned Costs - None Identification of How Questioned Costs Were Computed N/A, refer to context below for additional information. Context - The Agency was required to submit one portal submission (Period 4), which contained lost revenue amounts during 2023. The Period 4 portal submission for lost revenue did not follow the acceptable options provided by HHS, as noted in the criteria above. The Agency reported to HHS it used option ii (2020 Budgeted Revenue) to calculate its lost revenue included in its portal submissions. However, the budgeted amounts for patient care revenue relating the Agency's fiscal years for 2021, 2022, and 2023 were not approved prior to March 27, 2020; therefore, option ii was not available to be used. The Agency should have selected option iii in its portal submissions. The Agency used the same methodology for the Period 2 portal submission, even though the budgets related to that full Period of Availability were not approved prior to March 27, 2020. As of June 30, 2023, the Agency was only required to complete portal submissions for Period 2 and Period 4. Cause and Effect - Review of the reporting guidance was not effective and led to the selection of a lost revenue methodology that was not available. As a result, the Agency selected an incorrect methodology option (option ii) for reporting lost revenue. Recommendation - We recommend that the Agency 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 Agency agrees option iii should have been used for portal submissions and will implement additional reviews over future award applications.

Corrective Action Plan

Condition: The Organization's controls in place for reporting submissions did not identify Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 4 reporting submission for lost revenue did not follow the acceptable options outlined by HHS. Additionally, the Period 2 reporting submission, completed in the previous year, did not follow the acceptable options. Planned Corrective Action: Thresholds will have a second individual (Controller or SVP for Finance) review future award applications that are one-time or unusual in nature. We will pay particular attention to review the terms carefully so that Thresholds does not misunderstand things (such as the acceptable options, as in this case). Contact person responsible for corrective action: Al Shoreibah, Chief Financial Officer Anticipated Completion Date: April 1, 2024.

Categories

Material Weakness Reporting

Other Findings in this Audit

  • 389332 2023-002
    Material Weakness
  • 389333 2023-002
    Material Weakness
  • 965773 2023-001
    Material Weakness
  • 965774 2023-002
    Material Weakness
  • 965775 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.958 Block Grants for Community Mental Health Services $1.55M
93.498 Covid-19 - Provider Relief Fund and American Rescue Plan Rural Distribution $1.42M
93.150 Projects for Assistance in Transition From Homelessness (path) $840,733
14.181 Supportive Housing for Persons with Disabilities $732,797
14.157 Supportive Housing for the Elderly $423,250
14.195 Section 8 Housing Assistance Payments Program $361,664
93.696 Certified Community Behavioral Health Clinic Expansion Grants $337,624
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $200,000
93.136 Injury Prevention and Control Research and State and Community Based Programs $197,459
14.267 Continuum of Care Program $143,693
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $140,465
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $111,024
16.838 Comprehensive Opioid Abuse Site-Based Program $79,727
93.959 Block Grants for Prevention and Treatment of Substance Abuse $71,701
64.033 Va Supportive Services for Veteran Families Program $57,567
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $51,418
93.242 Mental Health Research Grants $20,526
14.231 Emergency Solutions Grant Program $7,503
14.239 Home Investment Partnerships Program $7,027
14.218 Community Development Block Grants/entitlement Grants $3,094