Finding 40099 (2022-001)

FINDING # 2022-001 Finding Criteria Discussion Program information Federal Program: COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured AL Number: 93.461 Federal Award Year: 2022 Criteria or requirement: Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal controls 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. Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding: During our testwork over allowability, we selected a sample of 60 payments for testing. Within our sample, we identified 1 selection where the charges submitted for reimbursement to HRSA were unallowable. Further, as the charges submitted were not properly reviewed this is an instance of the Health System?s internal control not operating as designed. Cause and possible asserted effect: The Health System does not have adequate processes and controls in place to ensure that all charges submitted for reimbursement under the HRSA Uninsured program are allowable. Without effective controls in place, charges could be reimbursed by the program that are considered unallowable, resulting in non-compliance with grant requirements. Identification of questioned costs and how they were computed: $347,249, representing the projected amount of unallowed charges reimbursed by HRSA Uninsured Program. Whether the sampling was a statistically valid sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number: No. Recommendations: We recommend that management strengthen processes and controls in place to ensure that all charges submitted to HRSA for reimbursement under the Uninsured Program are appropriately reviewed prior to submission to ensure they are allowable. Views of responsible officials: Management agrees with the finding, and notes that this was caused by an inadequate level of review performed prior and subsequent to submission to the program for reimbursement. Providence will prioritize strengthening our processes and controls before proceeding. Providence will add a layer of review for all potential new claims. All accounts will be audited by management prior to submission to ensure compliance. Providence will do a post submission audit to confirm billing compliance on paid claims.