Finding 520098 (2022-003)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2025-01-24

AI Summary

  • Core Issue: A refund of $324,825.67 for Unemployment Insurance costs turned previously allowable expenses into unallowable ones.
  • Impacted Requirements: The Organization must address the change in expense status to comply with HRSA guidelines.
  • Recommended Follow-Up: Communicate with HRSA to discuss replacing unallowable expenses with unreimbursed lost revenues in the corrective action plan.

Finding Text

Criteria In accordance with Health Resources and Services Administration Provider Relief Fund and American Rescue Plan, as required by The Post-Payment Notice of Reporting Requirements states that PRF payments can be used by any provider of health care, services, and support in a medical setting, at home, or in the community towards health care-related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse, which may include General and Administrative or health care-related operating expenses. Questioned Costs Subsequent to the end of the contract period and reporting deadlines, Unemployment Insurance costs claimed as a contract expense were refunded by New York State. These refunds in the amount of $324,825.67 resulted in the claimed expense becoming unallowable. Context The Organization had complied with the reporting requirements of the contract as the expense was allowable at the time of reporting. Due to subsequent events in which a refund was provided, the cost became unallowable. Cause Due to a New York State Unemployment Insurance Benefits and Department of Labor review of unemployment insurance charges, the Organization was refunded $324,825.67 because of a reduction in those charges. That reduction resulted in contract overpayments related to subsequently to unallowable expenses. Effect Previously allowed expenses became unallowable and the Organization may be required to return those funds in the amount of $324,825.67 to Health Resources and Services Administration (“HRSA”). Unless HRSA agrees to replace the unallowable expenses with unreimbursed lost revenues in the reporting period. Recommendation We recommend that the Organization communicate with “HRSA” regarding the subsequent refund of Unemployment expense and its intent to replace these now unallowable expenses with unreimbursed lost revenues. This may be reported in the Organizations corrective action plan where “the provider would indicate that the unallowable expensed was “replaced” by unreimbursed lost revenues. Reportinv Views of Responsible Officials See Corrective Action Plan.

Corrective Action Plan

Finding No: 2022-003 Questioned Cost Due to Subsequent Events Response: Agree Planned Corrective Action: The Company, having complied with the disbursement at the time incurred, agreed that a ‘Question Cost’ aroused by the subsequent credit issued and applied to the account by NYS UIB. Management is to report the amount of $324,825.67 to HRSA as Questioned Cost, and request HRSA approval for an election to apply this amount against unreimbursed lost revenue, in the reporting period. Guided by FQA HRSA report of February 16,2024 bullet option 2, page 16, on Question Cost per 45 CFR §75.2. “For providers that were not required to report in subsequent reporting period and chose to replace its unallowable expenses with its unreimbursed lost revenues in the reporting period in question” In the corrective action plan, the provider would indicate that the unallowable expense was “replaced “by unreimbursed lost revenues” Anticipated Completion Date: January 31, 2025.

Categories

Questioned Costs Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 520096 2022-001
    Significant Deficiency
  • 520097 2022-002
    Significant Deficiency
  • 1096538 2022-001
    Significant Deficiency
  • 1096539 2022-002
    Significant Deficiency
  • 1096540 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $1.35M