Finding Text
Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility, N. Special Tests and Provisions Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (COVID-19 Uninsured Program) Award Period: July 1, 2021 through June 30, 2022 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (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).? Health and Human Services (HHS) ? Health Resources and Services and Administrative (HRSA) issued Terms and Conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (T&Cs) outlining requirements that recipients of funding from the HRSA COVID-19 Uninsured Program must comply with including the following sections: Testing Services, Treatment Services and Vaccine Administration, and General Provisions in FY2022 Consolidated Appropriations. Condition: UC Health did not timely execute or retain supporting documentation for all internal controls pertaining to compliance with the HRSA COVID-19 Uninsured Program T&Cs. While management has processes in place to review claims for potential insurance coverage before initial billing, evidence of insurance reviews and subsequent verification of lack of coverage was not retained. Refunds required to be made to the HRSA COVID-19 Uninsured Program were not identified timely. Cause: UC Health did not design or appropriately document internal controls to monitor the T&Cs and underlying HRSA COVID-19 Uninsured Program regulations during the COVID-19 pandemic. Additionally, UC Health did not have internal controls in place to formally document its compliance with the HRSA COVID-19 Uninsured Program?s allowability and eligibility requirements. Standard policies, procedures, and internal controls over the review for patient insurance coverage and review of credit balances used in the federal program were not suitability designed to address the unique aspects of the HRSA COVID-19 Uninsured Program. Effect or potential effect: UC Health could be in noncompliance with the HRSA COVID-19 Uninsured Program T&Cs. A patient may not be uninsured and therefore the related encounter may be ineligible for reimbursement under the HRSA COVID-19 Uninsured Program. Credit balances may not be resolved timely and refunds to the HRSA COVID-19 Uninsured Program may not be identified or completed in a timely manner. Questioned costs: None. Context: We inquired of management, who indicated internal controls over the determination of the eligibility of certain patient encounters were not effectively designed or were not operating effectively. For these patient encounters, documentation pertaining to the execution of internal controls was not adequately retained. Further, internal controls were not appropriately designed to evidence retroactive approval of alternative insurance or credit balance review of accounts billed to HRSA. Identification as a repeat finding, if applicable: This finding is a repeat of the internal control portion of the 2021-001 finding included in the June 30, 2021, Single Audit Report. Recommendation: Management should implement document retention policies in order to subsequently support the design and implementation of internal controls over its review and compliance with the HRSA COVID-19 Uninsured Program T&C?s. Management should design and implement sufficiently precise internal controls to review changes to the HRSA COVID-19 Uninsured Program to ensure it is administering the program in compliance with the HRSA COVID-19 Uninsured Program regulations. In addition, internal controls should be designed and implemented to ensure claims submitted to the HRSA COVID-19 Uninsured Program meet the allowability criteria established by the HRSA COVID-19 Uninsured Program regulations before claims are submitted to HRSA for reimbursement. Standard policies, procedures, and internal controls over the review for retroactively applied alternative patient insurance coverage should be updated to address the unique aspects of the HRSA COVID-19 Uninsured Program. Evidence of insurance discovery to verify third-party insurance searches are completed with no other insurance identified should be maintained. Views of responsible officials: Management agrees with this finding and the need to update documentation policies and work procedures to ensure compliance with HRSA COVID-19 Uninsured Program regulations. However, management acknowledges that the HRSA COVID-19 Uninsured Program stopped accepting new claims in March 2022, and thus remaining work pertaining to the program is limited to resolution of existing claims. This minimizes the amount of policy and work procedure updates deemed necessary.