GARNET HEALTH

Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: COVID-19 - HRSA COVID-19 Claims Reimbursement for the Uninsured Program (the Uninsured Program) Federal Assistance Listing No.: 93.461 Criteria or Specific Requirement: The Uniform Guidance 2 CFR section 200.303 states, ?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).? The Uniform Guidance 2 CFR section 200.510 states, ?(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with ?200.502 Basis for determining Federal awards expended.?. Condition: The System did not provide an accurate listing of all expenditures for the Uninsured Program as presented in the SEFA. Cause: The System?s internal controls in place over the preparation of the SEFA were not sufficient to accurately report all expenditures of federal awards for the Uninsured Program. Effect or Potential Effect: The SEFA prepared by the System was misstated but was subsequently corrected. A misstated SEFA could result in the improper selection of federal award major programs or an incorrect percentage of coverage being calculated, resulting in a restatement of a previously issued Uniform Guidance report. Questioned Costs: None. Context: Expenditures for the major program were not accurately reported or adjusted in the SEFA in a timely manner. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Management should review its policies and procedures and internal controls over the process of accumulating and reporting expenditures of federal awards for the Uninsured Program. Views of responsible officials: Management concurs with the audit finding. Management will refine its controls and update standard work documentation to ensure that all expenditures for the Uninsured Program are appropriately accumulated and reported in the SEFA for the period covered by the System?s financial statements in accordance with Uniform Guidance 2 CFR section 200.502. All staff working on SEFA preparation will receive additional education in reporting for the Uninsured Program.

Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: COVID-19 - HRSA COVID-19 Claims Reimbursement for the Uninsured Program Federal Assistance Listing No.: 93.461 Criteria or Specific Requirement: 2 CFR 200.303 requires that a 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 and 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 FY2020 Consolidated Appropriations. A. Activities Allowed or Unallowed ? Activities allowed include required health services as described in the terms and conditions of the award for uninsured individuals, including reimbursement of payments for COVID-19 testing, testing-related items, treatment, or vaccine administration fees for individuals who do not have any health care coverage at the time the services were rendered. E. Eligibility ? Services must be for individuals, who at the time the services were provided, were uninsured as described in the terms and conditions of the award. Condition: Certain claims submitted to HRSA for reimbursement were not in compliance with the program?s terms and conditions for participation. Certain claims were submitted for insured individuals or for services rendered that were unrelated to COVID-19. Cause: Management?s review control to verify whether claims being submitted to HRSA were in accordance with the terms and conditions of the award was not consistently performed. As a result, management?s control did not detect the errors identified above and the claims were submitted to HRSA. Effect or Potential Effect: The inconsistent application of management?s control over these compliance requirements resulted in noncompliance including questioned costs. Questioned Costs: Questioned costs of $1,246 were identified, representing payments received from HRSA on claims for which the System did not comply with the terms and conditions of the program. The total sample value tested was $78,827 and total program expenditures in 2020 were $988,371. Context: In a sample of 60 claims, three claims were found to be noncompliant with the program?s terms and conditions: - One COVID-19 testing claim was identified as having active insurance coverage. - Two COVID-19 testing claims were submitted to HRSA including services rendered that were unrelated to COVID-19. All claims described above were submitted to, and reimbursed by, HRSA. Identification as a repeat finding: This finding is not a repeat finding from the prior year. Recommendation: Prior to claim submission, management should review the services rendered to ensure claims for reimbursement to HRSA are submitted for services rendered related to COVID-19 and in line with the terms and conditions of the program. Management should also refine its control to ensure that claims are being fully assessed for insurance coverage, utilizing insurance records on hand, prior to submitting claims to HRSA. Views of responsible officials: Management concurs with this finding and is in the process of performing a review of claims submitted to the HRSA COVID-19 Uninsured Program for potential payments related to patients with active insurance coverage and inclusive of services rendered that were unrelated to COVID-19. In March 2022, HRSA announced the discontinuance of the HRSA COVID-19 Uninsured Program and therefore remediation of internal controls is no longer applicable.