Finding 558160 (2021-004)

Material Weakness
Requirement
ABL
Questioned Costs
$1
Year
2021
Accepted
2025-04-30
Audit: 355035

AI Summary

  • Core Issue: The Organization reported $1,566,926 in Provider Relief Fund expenses without adequate documentation to support their eligibility, leading to questioned costs.
  • Impacted Requirements: Reporting and allowable costs criteria were not met, as expenses were not properly attributed to COVID-19 and some were reimbursed by other sources.
  • Recommended Follow-Up: Update policies and procedures to ensure compliance with federal grant reporting and that only eligible expenses are charged to the grants.

Finding Text

Federal Assistance Listing No. 93.498 U.S. Department of Health and Human Services COVID-19- Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Criteria or Specific Requirement – Reporting (45 CFR 75.342) and Activities Allowed/Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622, Pub. L. No. 116-260, Pub. L. No. 117-2) Condition – Within the Provider Relief Fund Reporting Portal for Period 1, the Organization reported other Provider Relief Fund (PRF) expenses and lost revenues calculated using option i. The Organization did not maintain adequate documentation to support some other PRF expenses were attributable to coronavirus, incurred following the accrual basis of accounting during the period of availability, and/or not eligible to be reimbursed by other sources. The Organization also did not calculate lost revenues following the accrual basis of accounting and other guidance issued by HHS. Questioned costs – $1,566,926; Calculated as total expense charged to PRF for Period 1. Context – The Period 1 PRF report was tested. The Organization allocated salaries and employee benefits to PRF for time associated with COVID-19 prevention activities; however, these salaries and benefits were not supported as incremental and necessary costs for the prevention, preparation and response to COVID-19 and a portion of these salaries and benefits were also reimbursed by other sources. The Organization calculated lost revenues of $668,478 based on patient service revenue information from the practice management system rather than lost revenues of $946,314 based on accrual basis financial records. Effect –Based on the Period 1 PRF report filed, the Organization utilized PRF payments received on expenses and lost revenues that were not attributable to coronavirus, were reimbursed by other sources, and/or were not allowable in accordance with other guidance issued by HHS. Cause – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution is a new program with complex and evolving regulations and compliance requirements. Internal controls were not in place to ensure the Organization correctly applied the guidance. Identification as a repeat finding – Not a repeat finding. Recommendation – Policies and procedures over allowable activities and federal grant reporting should be modified to ensure expenditures charged to grants are for activities allowed and federal grant reports are prepared using complete and accurate information.

Corrective Action Plan

Management acknowledges the finding. We will update and refine our grant policies and procedures to ensure that all grant expenses and revenue calculations comply with federal guidelines. A standardized review process will be implemented to validate expenditures, ensuring they are in alignment with the grant’s budget and not reimbursed by other sources. Documentation standards will be reinforced to ensure proper support for all grant expenses and revenue calculations. The finance team will verify that all revenue calculations follow the accrual basis of accounting, as required by HHS guidance. We will implement internal review and approval processes before submitting future grant reports. Periodic internal audits will be conducted to confirm compliance with uniform guidance guidelines and identify any potential reporting discrepancies. A designated compliance officer or team will oversee federal grant reporting to ensure adherence to evolving federal requirements. Staff involved in federal grant reporting and financial management will receive targeted training on grant compliance requirements, including allowable costs, proper revenue calculations, and documentation best practices. Regular updates will be provided to finance and grants management personnel to ensure continued compliance with evolving federal regulations. Replacement COVID-19 related costs of $1,566,926 were identified to evidence the spend down of period one Provider Relief Funds. These funds are not subject to repayment as the Organization was able to attest and comply with the terms and conditions of the funding, including demonstrating that the distributions received were used for qualifying expenses or lost revenue attributable to COVID-19. The above corrective actions are currently being implemented.

Categories

Questioned Costs Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 558148 2021-002
    Significant Deficiency Repeat
  • 558149 2021-003
    Significant Deficiency Repeat
  • 558150 2021-002
    Significant Deficiency Repeat
  • 558151 2021-003
    Significant Deficiency Repeat
  • 558152 2021-002
    Significant Deficiency Repeat
  • 558153 2021-003
    Significant Deficiency Repeat
  • 558154 2021-002
    Significant Deficiency Repeat
  • 558155 2021-003
    Significant Deficiency Repeat
  • 558156 2021-002
    Significant Deficiency Repeat
  • 558157 2021-003
    Significant Deficiency Repeat
  • 558158 2021-002
    Significant Deficiency Repeat
  • 558159 2021-003
    Significant Deficiency Repeat
  • 1134590 2021-002
    Significant Deficiency Repeat
  • 1134591 2021-003
    Significant Deficiency Repeat
  • 1134592 2021-002
    Significant Deficiency Repeat
  • 1134593 2021-003
    Significant Deficiency Repeat
  • 1134594 2021-002
    Significant Deficiency Repeat
  • 1134595 2021-003
    Significant Deficiency Repeat
  • 1134596 2021-002
    Significant Deficiency Repeat
  • 1134597 2021-003
    Significant Deficiency Repeat
  • 1134598 2021-002
    Significant Deficiency Repeat
  • 1134599 2021-003
    Significant Deficiency Repeat
  • 1134600 2021-002
    Significant Deficiency Repeat
  • 1134601 2021-003
    Significant Deficiency Repeat
  • 1134602 2021-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.527 Grants for New and Expanded Services Under the Health Center Program $2.29M
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $1.57M
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $660,721
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $38,362
93.526 Grants for Capital Development in Health Centers $10,872