Finding 5692 (2021-005)

Significant Deficiency
Requirement
BL
Questioned Costs
$1
Year
2021
Accepted
2023-12-20
Audit: 7666
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Hospital reported $147,682 in COVID-19 supply expenses that were eligible for reimbursement from other sources, violating funding guidelines.
  • Impacted Requirements: Expenses must be reported accurately, and internal controls are needed to ensure compliance with federal award terms.
  • Recommended Follow-Up: Enhance understanding of reporting guidelines and strengthen internal controls for future expense reporting.

Finding Text

Finding: Allowable Costs/Cost Principles and Reporting U.S. Department of Health and Human Services Direct Program: COVID-19 Provider Relief Fund and the American Rescue Plan (ARP) Rural Distribution - 93.498 Criteria or Specific Requirement – Activities Allowed/Unallowed and Cost Principles (Pub L. No. 116-136, 134 Stat. 563 and Pub L. No. 116-139, 134 Stat. 622 and 623). The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, P.L. 116-136) to reimburse, through grants or other mechanisms, eligible health care providers for increased expenses or lost revenue attributable to Coronavirus Disease (COVID-19). Entities that received more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. In addition, management is responsible for establishing and maintaining effective internal controls over costs directly and indirectly charged to federal awards. Condition – The Hospital claimed and reported COVID-19-related supply expenses within the HHS PRF portal that were eligible to be reimbursed via other sources. Questioned Costs – $147,682 of expenses were charged and reported which were available to be reimbursed by other sources. This was calculated by taking the supply expenses and multiplying this amount multiplied by the Hospital's internally calculated Medicare reimbursement rate. Context – Upon testing the compliance requirements of this program, it was determined certain expenditure items were being claimed and reported incorrectly as they were not "Medicare-affected" to reduce the portion of expense to be reimbursed by another source. Effect – The Hospital submitted and reported expenses which did not adhere to the terms and conditions of the award. Cause – The guidance provided by HHS to providers across the country as to how to report their COVID-19-related expenses and lost revenues is, at times, difficult to comprehend and apply. The Hospital incorrectly applied guidance. Identification as a Repeat Finding – Not applicable. Recommendation – The Hospital should continue to improve understanding of the nuances within the guidance as it relates to charging and reporting direct expenses. Additionally, the Hospital should implement additional controls over future reporting periods to help ensure guidance is followed. View of Responsible Official and Planned Corrective Actions – The Hospital agrees with this finding. See separate auditee document for planned corrective action.

Corrective Action Plan

The Hospital claimed and reported COVID-19-related supply expenses within the HHS Provider Relief Fund portal that were eligible to be reimbursed via other sources due to not reducing the amount of COVID-19 supply related expenses by the internally calculated Medicare reimbursement rate. Corrective Action Plan: While errors were identified within the COVID-19 expenses reported by the Organization, calendar year 2020 lost revenues, calculated using a budget approved prior to March 27, 2020, result in total lost revenues of $5,115,335. 2020 lost revenues alone more than substantiate the $4,503,732 of Provider Relief Funds recognized by the Hospital, regardless of any errors identified in COVID-19 expenses. Going forward, the Hospital will work to improve controls surrounding the tracking of COVID-19 related expenses and will ensure an individual, independent from the tracking of COVID-19 expenses, is reviewing reported expenses for accuracy and reasonableness. Personnel Responsible for Corrective Action: Kathleen Bunting, Chief Executive Officer; kjbrnmsn@hotmail.com; 618-842-2611. Anticipated Completion Date: Change is in process and full adoption is anticipated at time of next portal submission, if any.

Categories

Questioned Costs Allowable Costs / Cost Principles Cash Management Reporting

Other Findings in this Audit

  • 5691 2021-004
    Material Weakness
  • 582133 2021-004
    Material Weakness
  • 582134 2021-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $11.52M
93.498 Provider Relief Fund $4.50M
93.697 Covid-19 Testing for Rural Health Clinics $597,846
21.019 Coronavirus Relief Fund $161,327
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $144,026
93.301 Small Rural Hospital Improvement Grant Program $10,833
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $8,000