Finding Text
Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
Assistance Listing Number 93.498
U.S. Department of Health and Human Services
Criteria or Specific Requirement – Reporting (45 CFR 75.342) and Activities Allowed/Unallowed and Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623)
Condition – The Organization is required to prepare and submit period-one Provider Relief Fund (PRF) reporting. This report is to be prepared using accurate financial information and submitted by the deadline established.
Questioned Costs – Unknown
Context – The period one PRF report was tested. The Organization selected option two to report lost revenues based on a comparison of quarterly budgeted patient revenues to actual. For this approach, budgeted revenues may only be used if the budget(s) covering the period of availability that ended June 30, 2021, were approved prior to March 27, 2020. The 2021 budget which covered budgeted revenues from January 1, 2021 through June 30, 2022, was approved after the required date. In addition, certain patient service revenue accounts were improperly excluded from quarterly revenues related to patient care.
Effect – Errors were made in lost revenues.
Cause – The Organization did not qualify to use option two to report lost revenues and should have used one of the two other options in reporting lost revenues. The Organization also improperly excluded certain patient service revenue components in their calculation.
Identification as a Repeat Finding – Not a repeat finding.
Recommendation – Policies and procedures over federal grant reporting should be modified to ensure reports are prepared using complete and accurate information.
Views of Responsible Officials and Planned Corrective Actions - The budget period for January through December 2021 was approved prior to year-end 2020. Our budgets would most likely not be accurate if we prepared the FY (CY) 2021 budget by March 2020, especially considering COVID unknowns, as we have been growing rapidly as a Federally Qualified Health Center(FQHC). There were frequent changes in the PRF payment reporting portal at the time after funds were received. We did confer with our outside audit team before reporting but possibly due the changes, we may have misunderstood, or checked the wrong box in reporting portal, as we did include our budgets showing approval dates and explanation of our process.
Our FQHC did show how we fully obligated the funds. The lost revenue mentioned was related to `contract with payer for Per Member Per Month', which we did not realize had to be included in reporting. It is recorded in General Ledger, but not the billing software per patient account, nor included in the submitted reports retrieved directly from our billing software at the time. The auditor did confirm our reported revenue was sufficient to cover funding received.
We are very careful about accurate reporting and review our policies. All of our policies were also reviewed during our HRSA OS Visit Sept 2021, along with our HRSA reporting for these PRF awards, with no findings, so we did not realize we had a problem until a higher level audit review as we finalized our 2021 audit this week. We had many delays in closing this 2021 audit year and this surfacing took us by surprise.
Planned Corrective Action: We will work with HRSA on resolution of the finding.
Anticipated Completion Date: Will work to resolve as soon as possible pending HRSA's review
Contact Person Responsible for Corrective Action:
Diane Pautz, CFO
West Hawaii Community Health Center, Inc.
75-5751 Kuakini Hwy, Ste 203
Kailua Kona, HI 96740
dpautz@westhawaiichc.org