Finding 60257 (2022-002)

Material Weakness
Requirement
ABL
Questioned Costs
-
Year
2022
Accepted
2022-12-22
Audit: 49773
Organization: Logan Health (MT)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The Corporation lacked formal review and approval processes for expenditure calculations related to the COVID-19 Provider Relief Fund, increasing the risk of noncompliance.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) was not met, as effective internal controls over federal awards were not established or maintained.
  • Recommended Follow-Up: Enhance internal control policies to ensure formal documentation of reviews is present for all supporting documentation and reports across all locations.

Finding Text

U.S. Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution Applicable Federal Award Number and Year ? Period 1 TIN #810530457 and #810247969 Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Material Weakness in Internal Control over Compliance Criteria ? 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The Corporation claimed expenses based on specifically identified COVID related expenses and COVID related incremental expenses. The Corporation selected Option i and Option iii to calculate lost revenue (this varied based on specific entity). Condition ? During our testing, we noted reviews were performed over individual eligible expenditures; however, there was no formal review or approval of the expenditure spreadsheet used to calculate the expenditures claimed for the federal program outside of the preparer at the LH Cut Bank location. The Corporation?s calculation of lost revenue claimed under the federal program as an allowable cost was not subject to a formal review or approval by a separate individual outside of the preparer at the LH Cut Bank location. In addition, there was no evidence retained that the Corporation?s special report submitted to the Department of Health and Human Services for Period 1 was reviewed and approved by a separate individual outside of the preparer at the LH Whitefish and LH Cut Bank locations. Cause ? The Corporation did not have an adequate internal control policy in place to ensure review and approval over tracking of other funding sources, lost revenue, or reporting was documented at all locations. Effect - The lack of adequate policies governing review increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs ? None reported.Context/Sampling - Detail testing was performed over eligible expenditures for activities allowed and unallowable and allowable cost/cost principles. A sample of 65 expenditures was tested which totaled $983,641 out of $22,638,825. The lost revenue for all applicable quarters was tested. Also, key line items of the special report submitted to the Department of Health and Human Services for Period 1 and 2 Reporting were tested. Repeat Findings from Prior Years ? No Recommendation - We recommend that the Corporation enhance internal control policies to ensure that formal documentation of reviews is present at for all supporting documentation and reports all locations. Views of Responsible Officials - Management agrees with the finding.

Corrective Action Plan

Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution CFDA #93.498 Finding Summary: There was no formal documentation of review and approval for overall expenses claimed, calculation of lost revenue, or the Corporation's special report by a separate individual outside of the preparer at two entities. Responsible Individuals: Craig Lambrecht, CEO, and Cole Turner, CFO. Corrective Action Plan: All tracking documents and reports will be reviewed by someone other than the preparer at all locations. The reviewer will sign off by email or by physical signature that they have reviewed and agree with support. Anticipated Completion Date: 3/31/2023

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 60258 2022-003
    Material Weakness
  • 60259 2022-004
    Material Weakness
  • 636699 2022-002
    Material Weakness
  • 636700 2022-003
    Material Weakness
  • 636701 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.498 Provider Relief Fund $37.31M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $723,706
93.461 Covid-19 Testing for the Uninsured $708,059
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $56,405
93.697 Covid-19 Testing for Rural Health Clinics $20,265