Finding Text
Finding 2022-001 ? Internal Control Deficiency over A. Activities Allowed or Unallowed Identification of the federal program: Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.498 Provider Relief Funds Award Period of Performance: Period 1 ? July 1, 2021 to June 30, 2022 Criteria or Specific Requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls. The non-Federal entity must: (a) Establish and maintain effective internal control 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The terms and conditions of the award requires the following: ? The recipient certified that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient certifies that it will not use the payment to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. ? The recipient shall submit reports as the secretary of Health and Human Services (HHS) determines are needed to ensure compliance with conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: Per discussion with management, the Company has processes and internal controls over the terms and conditions of the award and transactional level internal controls in place to ensure Coronavirus related expenses reported to HHS through their reporting portal (the Portal). However, management did not retain documentation evidencing the performance of these controls. Effect or potential effect: There is no documentation to support the performance of internal controls for the term and conditions of the award and the expenses attributable to Coronavirus calculation. Questioned Costs: None Context: During our testing over the PRF program, we observed that management did not retain evidence of controls surrounding the terms and condition of the award and the calculation of expenses attributable to Coronavirus reported during July 1, 2021 to June 30, 2022. Identification as a repeat finding, if applicable: The finding is a repeat finding. Recommendation: Management should refine its process and retain documentation evidencing that management adheres to the terms and conditions of the award and retain documentation evidencing that management reviewed the completeness and accuracy of expenses attributable to Coronavirus calculation. View of Responsible Officials: Management agrees with the finding. Management will develop internal controls to review and approve supporting documentation and calculations of the Provider Relief Fund federal expenditures and terms and conditions.