FINGER LAKES REGIONAL HEALTH SYSTEM INC. DBA FINGER LAKES HEALTHNon-Profit

Criteria The System is required to disburse Pell and Direct Loan funds to student accounts no earlier than 10 days before the start of the semester. Condition/Context As part of our compliance testing, we note that for 3 selections tested, that the System disbursed funds greater than 10 days before the start of the semester. Cause The System utilizes a third-party student account servicer, and relies on them heavily for the administration of student financial aid. There are not currently sufficient oversight controls in place to ensure that funds are not disbursed earlier than 10 days before the start of the semester. Effect The System did not demonstrate compliance with the disbursement requirement for the accounts tested. Recommendation We recommend that the System establish oversight practices to ensure that compliance is met. Views of Responsible Officials The System will be terminating the contract with the outside third party and bringing administration of the program internal to increase communications and verifications of the start and ending dates of our programs. Monthly meetings will continue to occur with financial aid, finance and the bursar to ensure that timing is within regulations. This will be effective January 1, 2025.

Finding 2022?001 ? Assistance Listing No. 84.425 ? COVID-19 Education Stabilization Fund Criteria The System is required to use procurement procedures for the acquisition of property or services under COVID-19 Education Stabilization Fund, HEERF funding in compliance with the competitive procurement requirements of the Uniform Guidance. The System must maintain records sufficient to detail procurement transactions for the acquisition of property or services, and documentation showing compliance with procurement requirements under the Uniform Guidance. Condition/Context As part of our compliance testing, we reviewed the HEERF institutional funds expended on acquisition of property or services. As a result of this review, we noted that competitive bidding procurement requirements for HEERF awards were not met and competitive bids were not obtained for the School of Nursing project funded by HEERF. Cause The System did not establish a formal documented procurement policy to ensure compliance with applicable requirements under HEERF awards and competitive bids were not obtained. While the System worked collaboratively with the general contractor in the selection of subcontractors for the capital projects, competitive proposals were not obtained for the general contractor in accordance with the requirements of the Uniform Guidance procedure standards. While the System did review and select subcontractors with input from the general contractor, the Systems process for bidding relative to the subcontractors, including the final review and engagement of the subcontractors was not documented. Effect Documentation was not sufficient to demonstrate compliance with applicable procurement standards. Recommendation We recommend that the System establish procurement policies to meet federal compliance requirements. Views of Responsible Officials Management agrees with the recommendation and will establish and document written procurement procedures and maintain sufficient documentation for transactions including acquisition of property or services to ensure competitive bidding is obtained.

Criteria The System is required to submit Period 1 and Period 2 Provider Relief Fund (PRF) reports to the Department of Health and Human Services (HHS). The reports require providers to account for and certify that eligible expenses and lost revenue are used to determine proper usage and recognition of funds. Condition/Context As part of our compliance testing, we reviewed certified submissions to the HHS portal for both Period 1 and Period 2. As a result of this review, we noted that certain eligible expenses were claimed in Period 1 that were also reimbursed through another source. Cause The System included certain eligible expenses in its Period 1 Provider Relief Fund reports due to evolving guidance and availability of funding streams at the time the reporting was due. Based on the guidance in existence and funds available at the time, management believed the System to be in compliance based on HHS Portal instructions at the time of submission. Additional funds were received subsequent to the Period 1 portal submission that could be used to reimburse the System for expenses previously reimbursed by HHS PRF. Effect While the System incurred more than sufficient eligible expenditures and lost revenues to exhibit that the System funds were fully utilized, not including the expenses that were reimbursed through another source, the reporting of the Period 1 expenditures was incorrect. Recommendation We recommend that the System maintain documentation that details they incurred enough eligible expenditures not reimbursed through another source and lost revenue to continue to qualify for the full amount of the funding, even though expenditures reported in the Period 1 submissions were reimbursed through another source. It is noted at this time, there is not a mechanism to amend the portal submission.