Finding Text
Finding 2023-001 - Significant Deficiency in Internal Control
Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural
Distribution
Assistance Listing Number: 93.498
Federal Agency: U.S. Department of Health and Human Services
Pass-Through Agency: N/A
Award Number: N/A
Award Year: 2022
Compliance Requirement: Activities Allowed/Unallowed, Allowable Costs/Cost principles, and
Reporting
Questioned Costs: Not Determinable
Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of
2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over
the Federal award to ensure compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. Recipients of Provider Relief Funds and American Resue Plan
(ARP) Rural Distribution (PRF) payments must also comply with the reporting requirements described
in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health
and Human Services. Segregation of duties is an integral component of internal controls intended to
prevent or decrease the occurrence of noncompliance due to error or fraud. Proper segregation of
duties should be evident in order to ensure that no single employee has control over all phases of a
transaction.
Condition and Context: The Corporation lacks proper segregation of duties with respect to the
calculation of lost revenue. Proper segregation of duties is necessary to prevent a situation where
one individual handles a transaction from beginning to end in order to reduce the potential for
noncompliance due to error or fraud. During the audit of the lost revenue calculation, six months out
of fifty-six were input incorrectly into the calculation from the source documents in error. Using the
correct revenue amounts for those six months results in a higher total of lost revenue for the period.
Effect: As a result of the lack of proper segregation of duties, noncompliance due to error or fraud
could occur without being detected and corrected, timely.
Cause: The lack of segregation of duties is due to the CFO taking sole responsibility for calculating
both lost revenue and incremental agency costs without a separate review process.
Recommendation: Management should implement a review process for these calculations.
View of Responsible Officials: The Corporation will have more than one person review the
reporting for covid funds. After the information is gathered and reported by the Chief Financial
Officer (CFO) but before the information is submitted, the Controller will be asked to review the
data. After review and documentation that there has been a review, the reporting will be submitted.