Finding 497923 (2023-001)

Material Weakness Repeat Finding
Requirement
ABHN
Questioned Costs
-
Year
2023
Accepted
2024-09-24
Audit: 320539
Organization: Advocate Aurora Health, Inc. (IL)

AI Summary

  • Core Issue: Internal controls for retaining supporting documentation on FEMA expenditures were inadequate, leading to potential inaccuracies in reported costs.
  • Impacted Requirements: Non-compliance with Section 200.303 of the Uniform Guidance regarding effective internal controls and documentation retention.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all supporting documentation is retained for FEMA expense reviews and approvals.

Finding Text

Finding 2023-001 Information on the Federal Program: Federal Agency: Department of Homeland Security Assistance Listing No.: 97.036 COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through: Wisconsin Emergency Management Agency Pass-Through Award Number: FEMA-4520-079-07A07-00 Pass-Through Award Period of Performance: January 20, 2020 through December 31, 2021 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “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).” Per the FEMA Project Worksheet Report #664571, under the Documentation Requirements Acknowledgement, “In accordance with 2 C.F.R. §200.333 as well as state and local record retention requirements, the Applicant acknowledges the requirement to maintain all documentation that supports this project application in its own files. This documentation will be required if the Applicant submits an appeal for additional funding, as well as in the case of any audits.” Condition: The Organization’s internal controls were not suitably designed to retain all supporting documentation over their review and approval of FEMA federal expenditures. Management did not retain supporting documentation to support the inventory usage reports used in the development of the FEMA expenditures. Cause: Management designed a process to accumulate and review expenditures related to the FEMA; however, for certain components of the review and approval the supporting documentation was not retained to evidence that the internal review was sufficiently designed and operating effectively throughout the process. Management did not retain supporting documentation to support the inventory usage reports used in the development of the FEMA expenditures. Questioned Costs: The amount of questioned costs are unknown, given the nature of this finding in which we were unable to support the underlying inventory usage reports which were a key input to the development of FEMA expenditures included on the Schedule. Context: The Organization recorded FEMA expenditures on the Schedule based on the number of units of the personal protective equipment (PPE) used during the period of performance outlined in the project worksheet times the average costs of each unit of PPE. The information used to develop the FEMA expenditures was obtained from the Organization’s inventory management system. Management did not retain supporting documentation to support the reliance on the inventory usage reports; therefore, the information from the inventory management system cannot be relied on for Uniform Guidance purposes. Management represented that they performed a review of FEMA expenditures but did not maintain evidence supporting all levels of review and approval of expenses under FEMA. We obtained the Organization’s FEMA project worksheet that reconciled to the schedule of expenditures of federal awards. We then selected a sample of 25 PPE items and agreed the items used and the average unit costs to the inventory management system. In addition, we compared the average unit cost to a third-party invoice to support the unit cost used. Management engaged a third party to perform a physical inventory of supplies at December 31, 2020 which included the PPE claimed in the FEMA obligation. The physical inventory was reconciled to the inventory management system. We selected a sample of inventory counts performed by the third-party agency and agreed the inventory counts back to the third-party records, noting no exceptions. A physical inventory was not performed at December 31, 2021. Total federal expenditures for Assistance Listing 97.036 recorded on the Schedule totaled $48,004,943 for the year ended December 31, 2023. Effect or Potential Effect: The amounts submitted for reimbursement and the FEMA reports submitted could be inaccurate or incomplete. Identification as a Repeat Finding, if Applicable: This is a repeat finding; see 2022-002. Recommendation: The Organization should design and implement internal controls that are sufficiently precise and require supporting documentation be retained over the review and approval of FEMA expenses. The Organization should retain evidence of internal controls related to access and change management over the report or a quality review process over the inventory reports. Management response: The FEMA personal protective equipment (PPE) claim covered two years, which are 2020 and 2021. As noted in the audit, the Organization engaged a third party to perform a physical inventory of supplies at December 31, 2020 which included the PPE claimed in the FEMA obligation. The physical inventory was reconciled to the inventory management system. The audit selected a sample inventory count performed by third party and agreed the inventory counts back to the third party records noting no exceptions. A physical inventory was not performed at December 31, 2021. Due to the COVID pandemic, there were unusual circumstances that precluded an annual physical inventory in 2021, due to the easy transmission of COVID-19, by breathing in air carrying droplets or aerosol particles that contain the SARS-CoV-2 virus when close to an infected person or in poorly ventilated spaces with infected persons. Noting there were no system changes to the inventory system during 2021, we relied on the prior year audits and internal control review of the inventory system to provide comfort for the Organization for reliance on the inventory usage for this FEMA claim. In addition to relying on past inventory documented audit controls, the Organization routinely reviews the supply expense generated from the inventory system.

Corrective Action Plan

A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the Advocate Aurora Health (AAH) Disaster Grant – Public Assistance (Presidentially Declared Disasters). AAH’s internal controls were not suitably designed to retain all supporting documentation over their review and approval of FEMA federal expenditures. Management did not retain supporting documentation to support the inventory usage reports used in the development of the FEMA expenditures. The FEMA personal protective equipment (PPE) claim covered two years, which are 2020 and 2021. As noted in the audit, Advocate Aurora Health engaged a third party to perform a physical inventory of supplies at December 31, 2020 which included the PPE claimed in the SEFA obligation. The physical inventory was reconciled to the inventory management system. The audit selected a sample inventory count performed by third party and agreed the inventory counts back to the third-party records noting no exceptions. A physical inventory was not performed at December 31, 2021. Due to the COVID pandemic, there were unusual circumstances that precluded an annual physical inventory in 2021, due to the easy transmission of COVID-19, by breathing in air carrying droplets or aerosol particles that contain the SARS-CoV-2 virus when close to an infected person or in poorly ventilated spaces with infected persons. Noting there were no system changes to the inventory system during 2021, we relied on the prior year audits and internal control review of the inventory system to provide comfort for Advocate Aurora Health for reliance on the inventory usage for this FEMA claim. In addition to relying on past inventory documented audit controls, Advocate Aurora Health routinely reviews the supply expense generated from the inventory system. With respect to future FEMA claim submissions, Advocate Aurora Health will subject the application and claimed expenses to a comprehensive management review for allowability with FEMA regulations and project obligations. Evidence of the management review will be maintained with the other source documentation for a period of at least three years, longer in the case for real property and equipment if the specific program warrants. Existing procurement and system controls will continue to be leveraged to ensure accuracy and completeness of all source data. Nan Nelson, SVP Region Chief Financial Officer, is responsible for this Corrective Action Plan.

Categories

Equipment & Real Property Management

Other Findings in this Audit

  • 1074365 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $48.00M
16.575 Crime Victim Assistance $1.12M
93.498 Provider Relief Fund $1.11M
93.788 Opioid Str $1.07M
93.399 Cancer Control $777,712
93.959 Block Grants for Prevention and Treatment of Substance Abuse $633,432
21.019 Coronavirus Relief Fund $385,792
93.958 Block Grants for Community Mental Health Services $356,371
10.136 American Rescue Plan Act of 2021 Loan Payment $355,879
16.735 Congressionally Recommended Awards $216,905
93.307 Minority Health and Health Disparities Research $178,424
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $169,774
84.116 Fund for the Improvement of Postsecondary Education $166,752
93.242 Mental Health Research Grants $155,292
93.889 National Bioterrorism Hospital Preparedness Program $135,000
93.350 National Center for Advancing Translational Sciences $130,471
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $115,663
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $109,589
16.588 Violence Against Women Formula Grants $88,182
93.778 Medical Assistance Program $53,537
21.027 Coronavirus State and Local Fiscal Recovery Funds $43,933
93.865 Child Health and Human Development Extramural Research $41,482
93.837 Cardiovascular Diseases Research $36,593
93.310 Trans-Nih Research Support $30,998
20.600 State and Community Highway Safety $28,084
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $27,259
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $27,209
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $16,469
93.866 Aging Research $14,304
93.566 Refugee and Entrant Assistance_state Administered Programs $10,815
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $9,902
93.279 Drug Abuse and Addiction Research Programs $8,479
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $8,470
10.555 National School Lunch Program $7,034
93.395 Cancer Treatment Research $4,000
93.226 Research on Healthcare Costs, Quality and Outcomes $2,681
10.558 Child and Adult Care Food Program $2,023