Finding Text
Criteria or Specific Requirement ? The Hospital is required to submit filings with the Health Resource and Service Administration (HRSA) with respect to the Provider Relief Fund (PRF). Such filings include reporting of COVID-19 costs and lost revenues, as defined. Providers are not allowed to use PRF payments to reimburse expenses that have been reimbursed from other sources. Condition ? The Hospital?s Provider Relief Fund filing with HRSA for Reporting Period 4 did not consider COVID-19 costs that were potentially already reimbursed with a Paycheck Protection Program (PPP) loan. The PPP loan was subsequently forgiven. Context ? The Hospital engaged an independent firm to prepare its PRF filing for Reporting Period 4. Cause ? That firm did not consider the possibility that COVID-19 costs reported to the PRF could have been previously reimbursed by a PPP loan. The Hospital did not detect this oversight in its review of the Reporting Period 4 filing. Effect or Potential Effect ? The allowable COVID-19 costs incurred by the Hospital for Filing Period 4 exceeded the Filing Period 4 PRF payments received. Also, the costs included on the PPP loan forgiveness application exceeded the PPP loan. The Hospital performed an analysis which concluded that no COVID-19 costs included in the PRF Period 4 filing were previously reimbursed through the PPP loan forgiveness. Also, the Hospital incurred significant COVID-19 costs in 2022 that were not reported in the Period 4 Filing due to the aforementioned excess of costs during 2020 and 2021. However, the initial lack of consideration of the PPP loan forgiveness is an internal control deficiency. Questioned Costs ? There are no questioned costs. As noted above, the Hospital has concluded that the filing for Reporting Period 4 does not include costs that were previously reimbursed. Recommendation ? We recommend that the Hospital implement review procedures for any future filings with HRSA that ensure consideration of all relevant rules and regulations. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and has taken steps to ensure any future filings consider all relevant rules and regulations.