Stonewall County Hospital District

COVID-19 Provider Relief Fund Federal Assistance Listing Number 93.498 U.S. Department of Health and Human Services Criteria: Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). The District is required to prepare and submit period one provider relief fund report to the U.S. Department of Health and Human Services. This report is to be prepared using accurate financial information and submitted by the deadline established. The funds cannot be used for expenses reimbursed or obligated to be reimbursed by other sources. Condition: The District reported COVID-19-related expenditures within the HHS Provider Relief Fund and American Rescue Plan (ARP) Distribution (PRF) portal that were reimbursed via other sources. Questioned Costs: $1,667,639. Questioned costs were estimated by taking the total amount of acceptable expenditures multiplied by the District’s internally-calculated Medicare reimbursement rate. Context: The District is certified by Medicare as a critical access hospital. The period one provider relief fund report was tested. The District’s calculation of allowable expenses did not consider the impact of cost reimbursement to reported health care expenses to document that Provider Relief Fund and American Rescue Plan (ARP) Distribution payments were not reimbursed by any other source. Effect: The District submitted expenses under the PRF program that are obligated to be reimbursed by another source. Cause: The guidance provided by HHS to providers across the country as to how to report their COVID-19-related expenses and lost revenues is, at times, difficult to comprehend and apply. Internal controls were not in place to ensure the District correctly applied the guidance. Recommendation: Management should ensure proper internal controls are put into place to ensure that allowable expenses reported are not reimbursed by any other source. Views of responsible officials and planned corrective actions: See attached corrective action plan.

Corrective Action Plan for Finding 2021-003 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting and Activities Allowed or Unallowed and Allowable Costs/Cost Principles Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to ensure reports are prepared using complete and accurate information. We will increase compensating controls for introducing additional oversight and review for future federal funding reporting. Lewis Robbins, CFO, will be responsible to ensure this is accomplished. The District had enough lost revenues related to Period 1, as reported in the Period 4 reporting submission, that the error determined in Finding 2021-003 will not result in a conflict with funding received. The Corrective Action Plan will be implemented by September 30, 2025.

COVID-19 Provider Relief Fund Federal Assistance Listing Number 93.498 U.S. Department of Health and Human Services Criteria: Reporting (45 CFR 75.342) and Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623). The District is required to prepare and submit period one provider relief fund report to the U.S. Department of Health and Human Services. This report is to be prepared using accurate financial information and submitted by the deadline established. Any construction in progress expenses must be for capital assets placed in services within the period of eligibility. Condition: The District reported COVID-19-related expenditures within the HHS Provider Relief Fund and American Rescue Plan (ARP) Distribution (PRF) portal for construction in progress items that were not placed in service within the period of eligibility. Questioned Costs: $760,229. Questioned costs were estimated by evaluating claimed expenditures for capital asset items not placed in service within the period of eligibility. Context: The period one provider relief fund report was tested. The District’s reporting of allowable expenses included construction in progress expenses incurred for assets not yet placed in service at the close of the period of eligibility. Effect: The District submitted ineligible expenses under the PRF program. Cause: The guidance provided by HHS to providers across the country as to how to report their COVID-19-related expenses and lost revenues is, at times, difficult to comprehend and apply. Internal controls were not in place to ensure the District correctly applied the guidance. Recommendation: Management should ensure proper internal controls are put into place to ensure that claimed expenses reported are allowable under the terms of the program. Views of responsible officials and planned corrective actions: See attached corrective action plan.

Corrective Action Plan for Finding 2021-004 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting and Activities Allowed or Unallowed and Allowable Costs/Cost Principles Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to ensure reports are prepared using complete and accurate information. We will increase compensating controls for introducing additional oversight and review for future federal funding reporting. Lewis Robbins, CFO, will be responsible to ensure this is accomplished. The District had enough lost revenues related to Period 1, as reported in the Period 4 reporting submission, that the error determined in Finding 2021-003 will not result in a conflict with funding received. The Corrective Action Plan will be implemented by September 30, 2025.