Beth Israel Medical Center and Affiliates

Finding 2020-001 Activities Allowed or Unallowed and Eligibility Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Assistance Listing No.: 93.461 Criteria or Specific Requirement: A. Activities Allowed or Unallowed ? Activities allowed include required primary health services as described in the terms and conditions of the award for uninsured individuals, including reimbursement of payments for COVID-19 testing and testing-related items for individuals who do not have coverage through an individual or employer-sponsored plan, a federal healthcare program, or the Federal Employees Health Benefits Program 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. 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).? Condition: Certain claims submitted to the Health Resources and Services Administration (HRSA) for reimbursement were not in compliance with the program?s terms and conditions for participation. Certain claims were submitted for insured individuals. Other claims were submitted for services unrelated to COVID-19 testing and/or testing-related services. BIMC?s controls did not prevent or detect this noncompliance. Cause: A control was not in place to verify that claims submitted to HRSA were in full compliance with the program?s terms and conditions. Management did not prevent services rendered that were unrelated to COVID-19 testing and/or testing related services from being submitted to HRSA for reimbursement. A control was performed utilizing a third-party service provider to verify that patients were uninsured at the time services were provided, prior to the initial submission of a claim to HRSA. However, based upon review of insurance information retained in BIMC?s billing system in conjunction with our audit procedures, it was identified that certain patients were insured at the date services were provided. Management?s controls did not detect the identified coverage that was present at the time services were rendered and did not prevent the associated claims from being submitted to HRSA. Effect or Potential Effect: The lack of an effective control over these compliance requirements resulted in noncompliance including questioned costs. Questioned Costs: Questioned costs of $7,623 were identified, representing payments received from HRSA on claims for which the terms and conditions of the program were not complied with. The total sample value tested was $22,238 and total program expenditures were approximately $554,000. Context: In a sample of 60 claims, 14 claims were found to be noncompliant with the program?s terms and conditions. Seven claims were submitted to, and reimbursed by, HRSA for services rendered that were not related to COVID-testing and/or testing related services. An additional seven claims were identified as having active insurance coverage identified subsequent to the claim being submitted to, and reimbursed by, HRSA. Recommendation: Management should review services rendered to ensure claims for reimbursement to HRSA are submitted for services rendered related to COVID-19. 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 agrees with the finding described above. BIMC is in the process of reviewing all amounts reimbursed by HRSA under the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured program. Any amounts that were reimbursed for services not related to COVID testing and/or testing related services will be returned. Any amounts received for a patient that had insurance at the time of service will also be returned. BIMC is in the process of implementing internal controls to ensure claims are not submitted for non-COVID-19 related services and for claims with insurance.

Section III?Federal Award Findings and Questioned Costs Finding Reference Number: 2019-001 Information on the federal program: U.S. Department of Education Student Financial Assistance Cluster (84.268 Federal Direct Student Loans; 84.063 Federal Pell Grant Program) Criteria or specific requirement (including statutory, regulatory or other citation) N. Special Tests and Provisions (Enrollment Reporting) Condition Under the Pell grant and ED loan programs, BIMC must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG). BIMC determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, BIMC must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as per 34 CFR section 690.83(b)(2) (Pell) and; 34 CFR section 685.309 (Direct Loans). When conducting the audit of enrollment reporting, we noted that of the six reports, four were submitted late and one was not submitted at all. Cause BIMC had been reporting both Campus and Program-level enrollment but failed to complete the Enrollment Reporting Roster timely as the Financial Aid Officer was not aware of submission due date, or extent of information needed, to satisfy this additional requirement. Effect or potential effect BIMC was not in compliance with the provisions of the regulations above. Questioned Costs None Section III?Federal Award Findings and Questioned Costs (continued) Context We noted the finding during our testing performed to evaluate BIMC?s compliance with enrollment reporting and disbursements. Specifically, we noted that of the six reports, four were submitted late and one was not submitted at all. Identification as a repeat finding Not applicable Recommendation We recommend that BIMC establish more formal policies and procedures to ensure timely completion of record keeping, as required by the ED. Views of responsible officials Phillips School of Nursing at Mount Sinai Beth Israel (?PSON?) experienced staff turnover during 2019 in the Bursar and Assistant Director of Financial Aid positions. During this time, the PSON Bursar, received two notifications from the Program Compliance Department of the U.S. Department of Education (?USDE?) regarding non-compliance with student enrollment to the National Student Loan Data System (?NSLDS?). Despite interactions with the NSLDS and assurances that the issues had been resolved, in mid-January of 2020, an email notification was received, which again cited non-compliance by the PSON. At this time, the Assistant Dean, reached out to the Program Compliance Department of the USDE and it was determined that although the PSON was reporting both Campus and Program-level enrollment to NSLDS, the PSON was not reporting every student on its Enrollment Reporting Roster. Of the ones that had been reported, 100% had been certified; however, the requirement was to report all students. In the course of a few days, the PSON was able to bring the number of open students down from 449 to 1. Management agrees it is the responsibility of PSON to comply in a timely manner with all USDE reporting requirements. The PSON does not expect a recurrence of this finding since the School has now enrolled in the National Student Clearinghouse, and that Agency will be reporting enrollment data to the NSLDS, on behalf of the PSON going forward.