Finding Text
Assistance Listing, Federal Agency, and Program Name 93.498, U.S Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Federal Award Identification Number and Year N/A, 2023
Pass through Entity N/A Direct funded
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding No
Criteria Per the Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, recipients may choose to apply PRF payments toward lost revenue using one of three options, up to the amount:
Option i: of the difference between actual patient care revenue;
Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenue; or
Option iii: calculated by any reasonable method of estimating revenue
When Option i or Option iii is used, reporting entities are required to report each quarter's revenue on a payor level, using the following categories: Medicare Part A or B, Medicare Part C (Medicare Advantage), Medicaid/Children's Health Insurance Program (CHIP), Commercial Insurance, Self Pay (No Insurance), and Other.
Condition While the total revenue amounts reported by the Organization were accurate, there were two quarters (the third and fourth quarters of calendar year 2021) where the amounts identified for individual payors were not correct by offsetting amounts. The Organization's controls in place for reporting submissions ensured that the grand totals for each quarter were correct, but did not identify that individual payor amounts were correct.
Questioned Costs None
Identification of How Questioned Costs Were Computed N/A Refer to context below for additional information.
Context While the reporting submission reported the revenue information at the appropriate level of detail (identified in the criteria section above), several of the amounts reported for various payors were incorrect. The variances were offsetting, and there was no impact to the total lost revenue amounts reported.
Cause and Effect Adequate review of the reporting submission was not completed to ensure the report was fully in agreement with the supporting schedules maintained by management. As a result, while the total lost revenue amounts reported were correct, several individual payor level revenue amounts were not correctly reported.
Recommendation We recommend the Organization implement controls to ensure reports are completed and submitted in accordance with the guidelines established by HHS.
Views of Responsible Officials and Corrective Action Plan The Organization agrees with this finding. The Organization will implement and document a secondary level of review prior to all submissions to ensure submitted amounts agree back to supporting documentation.