Finding Text
Finding 2022-001 ? Activities Allowed or Unallowed and Eligibility Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 HRSA COVID-19 Claims Reimbursement for the Uninsured and the COVID-19 Coverage Assistance Fund Federal Award Numbers: Various Federal Award Period of Performance: September 1, 2021 to April 5, 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: As part of our testing of the Company?s internal control over allowability as it relates to all accounts identified with a potential COVID-19 account billing indicator that are subsequently reviewed by the Company to determine whether the account can be billed to the HRSA COVID-19 Claims Reimbursement for the Uninsured program, we identified a population of accounts that were improperly excluded from the review for the period September 1, 2021 to December 31, 2021. Cause: The original script to capture potential accounts for the HRSA COVID-19 Claims Reimbursement for the Uninsured program did not include accounts that had a zero balance and/or were in a closed status. Effect or potential effect: Accounts existed that might have been able to be billed to the HRSA COVID-19 Claims Reimbursement for the Uninsured program. Questioned costs: None. Context: Forty accounts were sampled from a population of 20,706 accounts identified with a potential COVID-19 account billing indicator. For 12 (30%) of the 40 accounts sampled, although the account was identified with a potential COVID-19 account billing indicator, the account was excluded from further review for potential billing to the HRSA COVID-19 Claims Reimbursement for the Uninsured program. These accounts were either related to the Company?s HealthLab financial assistance scoring or the patient was previously approved for Company financial assistance, and so these accounts were adjusted off to financial assistance shortly after the account qualified for billing. It was determined that a total of 2,098 (10.13%) accounts were excluded from the Company?s HRSA review for the period September 1, 2021 to December 31, 2021, and, of these 2,098 accounts, 1,898 (90.47%) related to lab accounts that averaged $165 to $190 in gross charges. Federal expenditures for Assistance Listing 93.461 totaled $2,907,040 for the year ended August 31, 2022. Identification as a repeat finding, if applicable: The finding is a repeat of finding 2021-001 from the prior year. Recommendation: The Company should ensure that review controls are properly designed. Views of responsible officials: In response to the prior-year finding, and after the fiscal year ended August 31, 2021, the Company redesigned its allowability review control to include these previously omitted accounts, as applicable and subject to timely claim filing requirements. The corrective action plan was completed and in place by December 31, 2021, shortly after the FY20 Uniform Guidance audit was completed on November 29, 2021. The HRSA COVID-19 Claims Reimbursement for the Uninsured program ceased to accept claims for testing and treatment effective March 22, 2022, and claims for vaccination were no longer accepted after April 5, 2022. Therefore, no further remediation is required at this time.