Finding Text
Finding 2022-005: Compliance with Reporting Requirements
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
COVID-19 – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution–
Assistance Listing No. 93.498
Compliance Findings: Reporting (L)
Criteria: Under the Provider Relief Fund Program, providers are required to submit reporting
to the Health Resources Services Administration (HRSA). For Periods 3 and 4, providers are
required to calculate and report ‘Total Lost Revenues for the Period of Availability’ and
‘Total Payments Used for Lost Revenues in the Previous Report Period’. Additionally,
providers are required to submit various personnel, patient and facility metrics.
Additionally, per 2 CFR 200.303, a non-Federal entity must 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 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: During our audit, it was noted that the amounts reported for ‘Total Payments Used
for Lost Revenues in the Previous Reporting Period’ did not properly report the $662,986 that
was claimed under Periods 1 and 2 of the program. Additionally, we were unable to test the
accuracy of the personnel, patient and facility metrics reported as the documentation to
support this information was unable to be located.
Cause: Internal controls in place were not sufficient to ensure accurate information, regarding
Period 1 and Period 2 ‘Lost Revenues Used’, was reported or that underlying records to
support information reported was retained.
Effect: The Organization is not in compliance with reporting requirements.
Context: Total ‘Lost Revenues for the Period of Availability’ significantly exceeds both the
‘Payments used for Lost Revenues in the Previous Reporting Period’ and the ‘Total Payments Used for Lost Revenues in the Current Reporting Period’. Therefore, the error is not
considered to be a material noncompliance with programmatic requirements.
Questioned Costs: $0
Identification of Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Organization review and improve its internal
control procedures to ensure accuracy of information reported. Additionally, we recommend
the Organization ensure internal control procedures include retaining documentation to
substantiate the information reported.
Views of Responsible Officials and Corrective Action Plan: Management agrees with this
finding and is in the process of developing internal controls to ensure records are retained in
accordance with policy. Additional details can be found in the Organization’s Corrective
Action Plan.