Finding Text
Section II ? Findings and Questioned Costs ? Financial Statement Findings See schedule of findings and questioned costs included in the Independent Auditors? Report on Internal Control over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards dated January 9, 2023. Section III ? Findings and Questioned Costs ? Major Federal Programs 2022-002 Federal agency: U.S. Department of Health and Human Services Federal program title: Provider Relief Fund Assistance Listing Number: 93.498 Award Period: Reporting period 2 for funds received from July 1, 2020, through December 31, 2020, used through December 31, 2021, and reporting period 3 for funds received from January 1, 2021, through June 30, 2021, used through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.303(a) states that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Health System did not have documented formal controls and procedures over compliance with federal awards for all expenditures. Condition: The Health System did not have documented formal review processes over the use of the federal awards for all expenditures. Eligible uses of federal awards were tracked in detail and reviewed, with formal approval documented on certain expenditures, but there was not a formal documented review process over whether expenditures were eligible under the federal award in all cases. Questioned Costs: None Context: The Health System maintained detailed records of eligible uses of federal funds for tracking and required reporting purposes. The Health System's Controller and CFO maintained this schedule as eligible uses of funds were identified throughout the organization, reviewed activity, and reconciled the schedule to the general ledger. There was not, however, documentation of a formal review or approval on all expenditures, outside of the schedule being maintained and reconciled. Management did also make regular reports to governance in monthly financial reports, including the use of COVID relief funds and board approval for certain uses of funds. These reports generally covered significant uses of funds and overall status updates on remaining funding, not a comprehensive report of all uses. The Health System does have in place review processes and controls over all expenditures (AP, Payroll), they are just not designed specifically to consider compliance with federal programs. Cause: The Health System has not previously received federal awards in an amount sufficient to require an audit under Uniform Guidance. Therefore, more formal controls and procedures around the use of federal awards had not been in place. The Provider Relief Fund, and certain other federal funds received in response to the COVID-19 pandemic were an unexpected occurrence. As the relief funds were distributed to the Health System, the focus of Health System's management and governance was on responding to the pandemic, and tracking use of related relief funds, and not necessarily on incorporating formal policies and procedures due to the time sensitive nature of the pandemic. In addition, detailed guidance surrounding the Provider Relief Fund was not immediately available and changed quite frequently over the period of the award, making it difficult for organizations to properly incorporate more formal policies and procedures. This finding was also present in the single audit for the year ended June 30, 2021, but due to the timelines of receiving and utilizing the funds and subsequently tracking and reporting them, the Health System did not have adequate time to address this significant deficiency prior to the single audit for the year ended June 30, 2022. Effect: Without formal control and review processes in place over use of federal funds or required reporting under those awards, there is a greater risk of improper use of funds or misstatement in required reporting. Repeat finding: Yes Recommendation: We recommend that management implement more formal control process surrounding the use of federal awards where there is segregation between individuals identifying or proposing expenditures/uses of funds and an individual reviewing and approving that expenditure/use. Documentation of review and approval should be retained in all cases. Views of responsible officials: There is no disagreement with the audit finding.