Finding 599183 (2022-001)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 18976
Organization: Christus Health (TX)

AI Summary

  • Core Issue: CHRISTUS Health failed to consistently document approvals for COVID-19 related expenses, indicating a lack of effective internal controls.
  • Impacted Requirements: This deficiency violates Section 200.303 of the Uniform Guidance, which mandates maintaining effective internal controls over federal awards.
  • Recommended Follow-Up: CHRISTUS should enhance its processes to ensure all COVID-related expenses are properly reviewed and documented to prevent ineligible charges.

Finding Text

Finding 2022-001 ? Internal Control Deficiency Over Activities Allowed or Unallowed Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: January 01, 2020 ? December 31, 2021 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: CHRISTUS Health (CHRISTUS) did not consistently retain documentation to evidence approval of certain expenses incurred related to COVID-19. Cause: CHRISTUS did not have controls in place to ensure amounts recorded as COVID-19 related expenses were reviewed and approved. Effect or potential effect: Lack of documentation of controls, including review and approval of expenses, may lead to ineligible expenses charged to the program. Questioned Costs: None. Context: We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding. CHRISTUS reported $12,991,294 of total expenses for the Period 2 HRSA Portal Submission. Identification as a repeat finding, if applicable: The finding is a repeat finding ? Finding 2021-001. Recommendation: CHRISTUS should refine its process to retain documentation evidencing that each expense recorded to the COVID accounts is reviewed and approved. View of Responsible Officials: Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances. We plan to review our processes related to the retention of expense documentation to improve audit evidence.

Categories

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility Material Weakness Period of Performance Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 22741 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $61.05M
93.461 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverage Assistance Fund $41.68M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.00M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $793,310
93.155 Rural Health Research Centers $528,681
93.650 Accountable Health Communities $525,067
16.575 Crime Victim Assistance $429,231
93.697 Testing and Mitigation for Rural Health Clinics $400,000
93.889 National Bioterrorism Hospital Preparedness Program $116,413
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $100,000
93.393 Cancer Cause and Prevention Research $93,657
93.994 Maternal and Child Health Services Block Grant to the States $86,660
93.395 Cancer Treatment Research $69,408
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $20,968
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $14,280
93.301 Small Rural Hospital Improvement Grant Program $10,969
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1,830