Finding 401146 (2021-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2021
Accepted
2024-06-18

AI Summary

  • Core Issue: There was a significant deficiency in internal controls over compliance, leading to discrepancies in reported expenditures for the COVID-19 Provider Relief Fund.
  • Impacted Requirements: The financial management system failed to provide accurate and complete reporting as required by §200.303 of 2 CFR Part 200, resulting in a $3.4 million reporting mismatch.
  • Recommended Follow-Up: Establish a process to segregate expenditures by funding sources from the start of the grant period and monitor compliance with individual program reporting requirements.

Finding Text

III. Section III – Federal Award Findings and Questioned Costs Finding 2021-001 – Internal Control over Reporting (Significant Deficiency) Federal agency: U.S. Department of Health and Human Services Federal program title: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution AL Number: 93.498 Award Period: Period 1 and 2 Reporting (Period of availability January 1, 2020 – December 31, 2021) Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the nonfederal entity’s financial management systems, including records documenting compliance with Federal Statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. Further, the financial management system of each non-federal entity must provide accurate, current, and complete disclosure of the financial results of each federal award or program, in accordance with the reporting requirements. Condition/Context: It was noted that the Other Provider Relief Fund (PRF) Expenses section was completed for the by-period program report, however the amounts did not agree to the final expenditure support. The final expenditure support exceeded the direct expenditures reported in the Other PRF Expenses and Unreimbursed Expenses Attributable to Coronavirus sections of the reports. In addition, the classification of the expenses by category and between periods per the final support did not match the period 1 and 2 reports. Questioned costs: None noted. Cause: Evolving guidance contributed to the condition. Management was diligent about segregating funding and expenditures for COVID-19 funding in total, but that approach made reporting for individual programs more difficult. Effect: The District did not accurately complete the program reporting as noted in the condition; however, the final support compiled for Other PRF Expenses exceeded the amounts reported in total for period 1 and 2 by $3.4 million. In addition, there was a total of $35 million of lost revenue in addition to the Other PRF Expenses. PRF was only applied to $6.5 million, which left unused lost revenue of $28.5 million at the end of period 2. Due to the condition noted above, the exact PRF that should have been applied to lost revenue in period 1 and 2 is not certain; however, there were no related questioned costs as there were unused lost revenues and supported Other PRF Expenses totaling $32 million. Repeat Finding: This is not a repeat finding. Recommendation: If the District continues to accept grant funding, we recommend that they create a process to ensure that expenditures are segregated by funding sources at the beginning of the grant period and the plan for individual program reporting requirement compliance is established and monitored. Views of Responsible Officials: The District believed they were following the reporting requirements at the time of submission based on the guidance available. After the submission they went through the process to segregate the PRF support more completely from other COVID-19 funding. While the classifications and PRF applied to Other PRF Expenses versus lost revenues within the program reports would have changed based on that process, in total amounts in excess of program expenditures for both periods were supported.

Corrective Action Plan

Finding 2021-001 Responsible Official: Matthew Vaughn, Regional Director of Financial Planning & Analysis Views of Responsible Officials: The District believed they were in compliance with the reporting requirements at the time of submission based on the guidance available. Guidance among the different federal programs changed over the course of the Public Health Emergency in a manner that caused reconsideration of both the classification and estimate of expenses. Over the course of the pandemic, the district went through the process to more completely segregate the PRF support from other COVID-19 funding. While the allocations and classifications within the program reports would have changed based on that process, in total program expenditures for both periods in total were supported. All expenses under the Public Health Emergency period have currently been categorized in this manner, and any future expenses or expense adjustments will be kept with this categorization in-tact. This was completed over the course of the 2021 Single Audit review in November 2023

Categories

Matching / Level of Effort / Earmarking Reporting Significant Deficiency

Other Findings in this Audit

  • 401147 2021-002
    Significant Deficiency
  • 977588 2021-001
    Significant Deficiency
  • 977589 2021-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $19.46M
93.461 Covid-19 Testing for the Uninsured $1.34M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.08M
93.697 Covid-19 Testing for Rural Health Clinics $204,819
32.006 Covid-19 Telehealth Program $38,515
93.301 Small Rural Hospital Improvement Grant Program $10,878