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 Rural Distribution (PRF) Federal Award Identification Number and Year - N/A - 2022 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 Distributions and American Rescue Plan Rural Distribution Post Payment Notice of Reporting Requirements dated October 27, 2022, infection control expenses paid with Nursing Home Infection Control distributions, allowable expenses may be reported as a use of targeted funds. Allowable expenses must be those that are unreimbursed by other sources and determined using the recipient's basis of accounting. Condition - ProMedica Health System's controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of infection control expenses in the correct period. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information. Context - The reporting submissions for certain HCR entities did not follow the guidelines published by the U.S. Department of Health and Human Services (HHS). These entities did not break out infection control expenses in the correct quarter in which they were expended. All infection control expenses were entered in quarter 1 and quarter 2 2022, regardless of if they were incurred in 2020 or 2021. Cause and Effect - Appropriate review of the expenses was not completed to ensure that eligible expenses were entered into correct period. As a result, the reports submitted were inaccurate, but the schedule of expenditure was not impacted. Recommendation - We recommend ProMedica Health System implement controls, including levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - Management fully understands and acknowledges the importance of identifying and complying with the reporting guidelines of federal awards, including the reporting of infection control expenses in the correct period. The receipt of Provider Relief Funds has broadened the scope of individuals that are responsible for reporting of Federal awards to those outside of the Grants and Research departments. Expenses for the Provider Relief Funds were correctly captured by period incurred and appropriately tracked for allowability. ProMedica has implemented a review procedure of the Provider Relief Funds consistent with other grant reporting so that the HRSA reports will be reviewed by a Grants Advisor or Grants Analyst prior to submission to ensure that eligible expenses are entered into the correct period in accordance with the guidelines established by HHS.