Finding Text
No. 2022-002 ? Activities Allowed or Unallowed; Allowable Costs and Eligibility ? Significant Deficiency in Internal Control Over Compliance Identification of the federal program: Federal Grantor: United States Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (Program) Pass-Through Award Numbers: Not applicable Pass-Through Award Period of Performance: 07/01/2021?06/30/2022 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).? Specific program terms and conditions established by HHS state that the program provides claims reimbursements to eligible health care providers for conducting COVID-19 testing for the uninsured, treating uninsured individuals with a COVID-19 diagnosis, and administering FDA-authorized or FDA-licensed COVID-19 vaccines to uninsured individuals. Condition: Management developed a robust process to ensure that amounts submitted to and reimbursed by the COVID-19 Testing for the Uninsured program were in accordance with federal program requirements. During our testing of such controls in place for this program, we were able to corroborate through inquiry of management and reperformance that the controls were in operation, however support that would allow us to inspect evidence as to the consistent operating effectiveness and precision included in the controls was not consistently retained. Cause: In certain instances, support that would allow us to inspect evidence as to the consistent operating effectiveness and precision included in the controls was not retained. Questioned costs: None. Context: Total federal expenditures for Assistance Listing 93.461 totaled $2,381,119 for the year ended June 30, 2022. We selected 60 transactions totaling $140,433 for testing. We did not identify any instances of noncompliance in our sample. Effect or potential effect: Potential effects include providing services to ineligible patients, services reimbursed by HRSA were not allowable or patients were inappropriately billed for services that HRSA reimbursed under this program. This could ultimately result in funds being received for ineligible patients and/or for unallowable services provided to patients. Identification as a repeat finding, if applicable: The finding is a repeat finding of Finding 2021-002 in the prior year. Recommendation: Management should retain documentation of the precision at which the controls were carried out as designed sufficient to test internal control over compliance.