Finding 42115 (2022-001)

Material Weakness
Requirement
ABL
Questioned Costs
-
Year
2022
Accepted
2023-03-08
Audit: 39579
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Organization incorrectly calculated lost revenue by including ineligible revenue items and selecting the wrong reporting option.
  • Impacted Requirements: Reporting must align with 45 CFR 75.342 and the Provider Relief Fund guidelines, ensuring accurate documentation of lost revenue and adherence to budget approval timelines.
  • Recommended Follow-Up: Enhance internal controls and understanding of reporting requirements to prevent future errors and ensure compliance with federal guidelines.

Finding Text

Criteria: Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, P.L. 116-136) to reimburse, through grants or other mechanisms, eligible health care providers for increased expenses or lost revenue attributable to Coronavirus Disease 2019 (COVID-19). Entities that receive more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. In addition, the Organization is required to implement and maintain internal controls over financial reporting. Condition: During our review of the Period 3 report submitted, we noted the Organization included revenue items that should not have been included in the lost revenue calculation and indicated that the calculation was under Option 2 but should have reported under Option 3. In addition, actual revenues and budgeted revenues included in the lost revenue calculation did not agree to the underlying accounting records and approved budgets. Questioned Costs: Unknown Context: Pharmacy revenue and grant revenue should not have been included in the lost revenue calculation and Option 2 required a budget to be approved by March 27, 2020 and not all of the budgets utilized in the reporting of Period 3 were approved by that deadline. The lost revenue calculation included actual and budgeted revenue amounts that did not agree to the underlying accounting records and approved budgets. Effect: The federal government relies on the information reported in the Health Resources and Services Administration (HRSA) to be accurate for monitoring purposes. Errors were made in reporting quarterly total revenue/net charges from patient care for each year, 2020, 2021, and 2022. and by selecting the incorrect option, the Organization did not submit the required narrative information to HRSA. Cause: The Organization did not have adequate internal controls in place to identify revenue amounts that should not have been included in the lost revenue calculation, that option 3 should have been selected for reporting and that the actual and budgeted revenues reported did not agree to the underlying accounting records and approved budgets. Identification as a repeat finding: Not a repeat finding. Recommendation: The Organization should continue to improve their understanding of the guidance related to this type of reporting and implement additional controls over future reporting periods to help ensure guidance is followed. Views of responsible officials: The Organization agrees with the finding. See separate report for planned corrective actions.

Corrective Action Plan

As stated in the audit findings, there were errors made in reporting lost revenue, which included pharmacy and grant revenue. Jefferson Center agrees there were errors made and are providing a solution for the corrective action plan. It?s every important for Jefferson Center for Mental Health to report accurately and timely information. All future reporting and correspondence on provider relief funding will be reviewed by multiple fiscal staff, including the Controller, Director of Finance and the Chief Financial Officer. Having multiple qualified staff to review and agree that the correct procedures have been followed and that the information being reported is accurate, will ultimately meet our goal of reporting 100% accurate information. In the future, the Controller will prepare the reporting information, the Director of Finance will assist the Controller in reviewing the reporting guidelines and timelines as well as assist with populating the reports with the correct data. The Chief Financial Officer will review the reports and data sources to ensure that we follow the correct reporting guidelines. Jefferson Center will also make sure that we have the latest Post-payment Notice of Reporting Requirements from the HRSA website to ensure we?re aware of the latest reporting requirements. Projected Completion Date: February 15, 2023 CLIENT RESPONSIBLE PARTY: Name of Contact Person: David A. Goff, MBA Vice President of Administration and Chief Financial Officer. 4851 Independence Street, Wheat Ridge, CO 80033. 303-432-5164, Davidg@jcmh.org

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management HUD Housing Programs Reporting

Other Findings in this Audit

  • 618557 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund (prf) and American Rescue Plan (arp) Rural Distribution $1.66M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $943,011
93.788 Opioid Str $375,810
93.982 Mental Health Disaster Assistance and Emergency Mental Health $335,786
93.958 Block Grants for Community Mental Health Services $333,205
21.027 Coronavirus State and Local Fiscal Recovery Funds $197,000
14.871 Section 8 Housing Choice Vouchers $167,475
14.267 Continuum of Care Program $137,375
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $91,843
14.218 Community Development Block Grants/entitlement Grants $87,785
14.181 Supportive Housing for Persons with Disabilities $39,148
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covi... $10,555
93.069 Public Health Emergency Preparedness $7,500
93.575 Child Care and Development Block Grant $2,840
93.758 Preventive Health and Health Services Block Grant Funded Solely with Prevention and Public Health Funds (pphf) $2,074