Finding 504720 (2022-003)

Significant Deficiency Repeat Finding
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2024-11-05
Audit: 327330
Organization: Inova Health System (VA)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance for the COVID-19 Provider Relief Fund, affecting the accuracy of federal award reporting.
  • Impacted Requirements: Internal controls must comply with Title 2 U.S. Code of Federal Regulations, Part 200.303, ensuring effective management of federal awards.
  • Recommended Follow-Up: Revise policies and procedures to ensure accurate reporting of expenditures as required by the Uniform Guidance.

Finding Text

Federal Program Information Federal Agencies: Department of Health and Human Services Awards: Assistance Listing Number 93.498 COVID 19 – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Periods: Period 3 – January 1, 2021 to June 30, 2022; Period 4 – June 30, 2021 to December 31, 2022 Description: Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency in Internal Control Over Compliance   Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “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.” Condition The System did not have appropriately designed internal controls in place to determine the correct amount of COVID 19 Provider Relief Fund (PRF) grant awards on the Schedule of Expenditures of Federal Awards (the Schedule) for the year ended December 31, 2022. Cause The Schedule for the year ended December 31, 2022 continued to include a number of COVID 19 programs. These programs did not follow the historical grant process and therefore, various individuals in the System were involved and responsible for monitoring the terms and conditions of the federal awards and reporting of the federal expenditures. Management did not design internal controls to accurately report expenditures within the Schedule. Effect or potential effect The reporting and verification of the completeness and accuracy of the expenditures included in the Schedule is not sufficient. Questioned costs None. Identification of a repeat finding This is a repeat finding and relates to prior year finding 2021-001.   Context We identified that the Schedule for the PRF grant awards did not include rural distributions of $1,483,532. Management reconciled the Schedule to the payments received as well as to the HHS Tracking Accountability in Government Grants System (TAGGS) database, which inappropriately excluded the rural distributions. Management subsequently corrected the amount and the federal expenditures reported on the Schedule include the rural distributions. Recommendation The System’s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of responsible officials There is no disagreement with the audit finding.

Corrective Action Plan

Federal Award Finding and Questioned Costs Finding Reference Number: 2022-003 Other Federal Program Information: Federal Agency: U.S. Department of Health and Human Services Awards: Assistance Listing Number 93.498 COVID-19 – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Periods: Period 3 – January 1, 2021 to June 30, 2022 Period 4 – June 30, 2021 to December 31, 2022 Description: Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: The System’s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and procedures will be created outlining processes and control activities to ensure reporting to federal awarding agencies and pass-through entities are complete and accurate. During the current fiscal year, Inova began implementing enhancements to Oracle’s Grants Accounting module. Once completed, this will assist management to automate certain processes and procedures that were not available after the initial implementation. The enhanced reporting capabilities will include automated reporting that will identify grants that expended federal awards. Grants Accounting will schedule quarterly meetings with Finance and GMO leadership present. The purpose of these meetings will be to review federal funding received that will ultimately be used in the preparation of financial reports submitted to the appropriate governing agencies. The Director of Grants Accounting will guide the meetings and obtain approvals from department leaders confirming amounts to be reported for federal grant awards. In preparation of the meetings, the Director of Grants Accounting will prepare an agenda to guide discussions of grant terms and conditions and applicable FAQs, more explicitly for awards received outside of Inova’s normal course of business (i.e., COVID-19). These meetings will also provide an opportunity for Finance, GMO, and Grants Accounting leaders to review the unique characteristics of the federal grant award programs on at least a quarterly basis. Meeting minutes will be maintained to document discussions and actions to be taken. The minutes will also serve as support for accounting memos related to special awards received that document Inova’s understanding of the award and related reporting requirements. All accounting memos will be prepared by the Director of Grants Accounting and reviewed by the Senior Director of Financial Reporting. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Planned completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2023.

Categories

Reporting Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 504718 2022-001
    Significant Deficiency Repeat
  • 504719 2022-002
    Material Weakness
  • 504721 2022-004
    Material Weakness
  • 1081160 2022-001
    Significant Deficiency Repeat
  • 1081161 2022-002
    Material Weakness
  • 1081162 2022-003
    Significant Deficiency Repeat
  • 1081163 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $31.63M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $12.42M
93.917 Hiv Care Formula Grants $3.05M
12.750 Uniformed Services University Medical Research Projects $2.36M
93.837 Cardiovascular Diseases Research $728,686
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $630,893
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $551,228
93.461 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $537,317
93.939 Hiv Prevention Activities Non-Governmental Organization Based $428,237
20.RD Nhtsa Discretionary Safety Grants and Cooperative Agreements $358,219
93.350 National Center for Advancing Translational Sciences $278,879
93.145 Aids Education and Training Centers $249,634
93.RD Population Health Research Support $203,128
93.914 Hiv Emergency Relief Project Grants $168,245
93.767 Children's Health Insurance Program $166,981
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $144,695
93.103 Food and Drug Administration Research $134,239
16.575 Crime Victim Assistance $126,935
93.393 Cancer Cause and Prevention Research $102,253
93.RD Nhlbi Graft Sample and Data Collection Project $80,705
93.394 Cancer Detection and Diagnosis Research $73,677
12.420 Military Medical Research and Development $40,278
93.226 Research on Healthcare Costs, Quality and Outcomes $35,161
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $32,135
93.RD Nhlbi/inova Pulmonary Vascular Program $27,759
93.397 Cancer Centers Support Grants $21,633
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $17,834
21.027 Coronavirus State and Local Fiscal Recovery Funds $13,427
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $13,326
93.RD Nhlbi Pulmonary Vascular Program $7,240
93.855 Allergy and Infectious Diseases Research $5,536
93.RD Support Services for the Lampoon Protocol Ide Enrollment Sites $4,248
93.940 Hiv Prevention Activities Health Department Based $2,126