Finding 404103 (2023-001)

FINDING 2023-001 – LOST REVENUE REPORTING Criteria As published in the October 27, 2022 Post-Payment Notice of Reporting Requirements, recipients who received one or more ARP Rural Distribution payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report in each applicable Reporting Time Period. For General Distribution Payments: A parent entity may report on its subsidiaries’ General Distribution payments regardless of whether the subsidiary TINs received the General Distribution payments directly from HRSA or whether General Distribution payments were transferred to them by the parent entity. The parent entity may report on these General Distribution payments regardless of whether the parent or the subsidiary attested to the Terms and Conditions. Condition Tufts Medicine received PRF funding between January 1, 2022 and June 30, 2022 and, therefore, was required to submit information for Reporting Period 5. All of the funds received during the time period were General Distribution funds. Therefore, Tufts Medicine, as the parent entity, was permitted to submit Reporting Period 5 on behalf of its subsidiaries. Tufts Medicine, as the parent entity, submitted Reporting Period 1, Reporting Period 2, Reporting Period 3, and Reporting Period 4 on behalf of its subsidiaries for all General Distribution funds received. Cause As a result of a change in staffing and internal miscommunication, Home Health Visiting Nurse Association (VNA) erroneously filed Reporting Period 5 separately from the Tufts Medicine filing, with data inconsistent with the previous filings and methodology. Effect The filing was not able to be removed or amended prior to the September 30, 2023 deadline. Consequently, the Tufts Medicine filing was not able to be submitted with the EIN of Home Health VNA. In order to file for all entities timely, the Home Health VNA EIN was excluded from the Tufts Medicine filing, but all financial data was included in the supporting lost revenue calculation. Recommendation The System should design and implement appropriate internal controls to comply with the reporting requirements, specifically to designate only certain personnel to be responsible for the PRF submissions to prevent any unauthorized submissions. Views of Responsible Officials See Corrective Action Plan