EIN: 221546163
UEI: RMJ9SKEWSXJ6
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 19, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 19, 2023 (1164 days ago).
What is a management decision? →During our testing of the PRF program, we noted that certain Coronavirus related expenses reported to HHS through their reporting portal (the Portal) were unallowable under the Terms and Conditions of the award. The Company?s controls did not prevent or detect this noncompliance. Cause: Management did not have effective internal controls over compliance in place to ensure Coronavirus related expenses reported to HHS through their reporting portal (the Portal) were allowable in relation to the terms and conditions of the award. Effect or potential effect: Unallowable expenditures were submitted to the Portal. Unallowable expenditures supporting General and Targeted Distributions ($31,499 of the questioned costs) could alternatively be supported by lost revenues, of which sufficient amounts were reported in the Portal. Unallowable expenditures supporting Skilled Nursing Facility and Nursing Home Infection Control Relief Payments ($526,713 of the questioned costs) cannot be alternatively supported by lost revenues under the terms and conditions of the award. Management believes that sufficient expenditures allowable under these terms and conditions were incurred, but incorrectly omitted from the Portal reporting. Questioned costs: $558,212 Context: During our testing over activities allowed or unallowed and allowable costs, we observed that management submitted expenses to support Skilled Nursing Facility and Nursing Home Infection Control Relief Payments that were not specifically incurred for infection control activities. Management also submitted expenses for General and Targeted distribution payments that were incurred in January 2020, before preparation for or prevention of the COVID-19 pandemic began at the Company. Finally, management submitted expenses for General and Targeted distribution payments that were unallowable under conditions imposed by HHS? reporting instructions. Identification as a repeat finding, if applicable: No Recommendation: Management should refine its control to ensure that submitted expenditures are allowable under the terms and conditions of the award and that reporting is accurate within the Portal. Views of responsible individuals: Management agrees with the finding. Management will develop internal controls to review and approve supporting documentation of the Provider Relief Fund federal expenditures and terms and conditions.
Show full finding ▾Hide full finding ▴Finding 2021-001 ? Material weakness and noncompliance over A. Activities Allowed or Unallowed and B. Allowable Costs, in regards to submission of expenses attributable to Coronavirus. Identification of the federal program: Assistance Listing Number 93.498: ? COVID-19 ? Provider Relief Fund (PRF) ? U.S. Department of Health and Human Services (HHS) ? Federal award identification number ? not applicable ? Federal award year ? Period 1 and Period 2 ? January 1, 2020 to December 31, 2020 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 terms and conditions of the award require the following: ? The recipient certified that it will use Skilled Nursing Facility and Nursing Home Infection Control Relief Payments for costs associated with infection control expenses. ? The recipient certified that the payment will only be used to prevent, prepare for, and respond to coronavirus, and that the payment shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. ? The recipient shall submit reports as the secretary of Health and Human Services (HHS) determines are needed to ensure compliance with conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: During our testing of the PRF program, we noted that certain Coronavirus related expenses reported to HHS through their reporting portal (the Portal) were unallowable under the Terms and Conditions of the award. The Company?s controls did not prevent or detect this noncompliance. Cause: Management did not have effective internal controls over compliance in place to ensure Coronavirus related expenses reported to HHS through their reporting portal (the Portal) were allowable in relation to the terms and conditions of the award. Effect or potential effect: Unallowable expenditures were submitted to the Portal. Unallowable expenditures supporting General and Targeted Distributions ($31,499 of the questioned costs) could alternatively be supported by lost revenues, of which sufficient amounts were reported in the Portal. Unallowable expenditures supporting Skilled Nursing Facility and Nursing Home Infection Control Relief Payments ($526,713 of the questioned costs) cannot be alternatively supported by lost revenues under the terms and conditions of the award. Management believes that sufficient expenditures allowable under these terms and conditions were incurred, but incorrectly omitted from the Portal reporting. Questioned costs: $558,212 Context: During our testing over activities allowed or unallowed and allowable costs, we observed that management submitted expenses to support Skilled Nursing Facility and Nursing Home Infection Control Relief Payments that were not specifically incurred for infection control activities. Management also submitted expenses for General and Targeted distribution payments that were incurred in January 2020, before preparation for or prevention of the COVID-19 pandemic began at the Company. Finally, management submitted expenses for General and Targeted distribution payments that were unallowable under conditions imposed by HHS? reporting instructions. Identification as a repeat finding, if applicable: No Recommendation: Management should refine its control to ensure that submitted expenditures are allowable under the terms and conditions of the award and that reporting is accurate within the Portal. Views of responsible individuals: Management agrees with the finding. Management will develop internal controls to review and approve supporting documentation of the Provider Relief Fund federal expenditures and terms and conditions.
Finding 2021-001 Please see management?s action plan below in response to EY?s Federal Award Finding and Questioned Costs, 2021-001 ? ?During our testing over activities allowed or unallowed and allowable costs, we observed that management submitted expenses to support Skilled Nursing Facility and Nursing Home Infection Control Relief Payments that were not specifically incurred for infection control activities. Management also submitted expenses for General and Targeted distribution payments that were incurred in January 2020, before preparation for or prevention of the COVID-19 pandemic began at the Company. Finally, management submitted expenses for General and Targeted distribution payments that were unallowable under conditions imposed by HHS? reporting instructions.? Management?s Response and Action Plan Access to Skilled Nursing Facility and Nursing Home Infection Control Relief Payments became available to health care providers, including ourselves, at a volatile and uncertain period during the early days of the novel worldwide COVID-19 pandemic. Retrospective and prospective rules governing access to and use of these funds, including related issued guidance, evolved during and after our receipt of these payments, particularly because of the novel nature of the virus. We welcome the opportunity to contribute our experiences toward improvement efforts by all parties in these unusual situations and objectively monitor and implement further strengthening of our controls. As a result, we have instituted controls that allow for continual and closer monitoring of evolving payment rules and regulations, especially in the midst of novel environments, to be certain that submitted costs and other data are consistent with those requirements and issued guidance, including covered periods and eligible costs. We understand that certain costs submitted by us that the auditors identified as out of compliance with evolving guidance for promulgated rules and regulations, did not result in our receipt of payments not otherwise permitted due to lost revenues, as identified during the auditors? related procedures.
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