THE HIGHLANDS AT WYOMISSING

#2021-001 - COVID-19 Provider Relief Fund - AL #: 93.498, Year Ended June 30, 2021 Criteria: The U.S. Department of Health and Human Services does not allow PRF monies to be used to reimburse expenses that have been reimbursed from other sources. Statement of Condition: The Highlands charged a portion of the PRF grant toward fringe benefits that had been applied to the Provider Paycheck Program (PPP) loan. Cause and Effect: The Highlands? management inadvertently charged a portion of the Federal Insurance Contributions Act (FICA) tax that had already been reimbursed from the PPP loan. Questioned Costs: None over the reportable threshold. Identification of Repeat Finding: No Recommendation: The Highlands should enhance its procedures to ensure that PRF monies are also not charged to other sources. Management Response: We concur with the recommendation and have immediately revised our procedures such that unique general ledger accounts, specific to each grant, including federal awards, will be created upon receipt.

#2021-002 - COVID-19 Provider Relief Fund - AL #: 93.498, Year Ended June 30, 2021 Criteria: The U.S. Department of Health and Human Services requires the recipient of PRF monies to maintain appropriate records and cost documentation as described in 45 CFR 75.361, Retention Requirements for Records. Statement of Condition: The Highlands did not maintain the account reconciliation master list evidencing second level approval for expenditure of grant funds. Cause and Effect: The Highlands? record retention policy did not specifically require the account reconciliation master list be retained. As a result, management approval of that list could not be verified. Questioned Costs: None Identification of Repeat Finding: No Recommendation: The Highlands? record retention policy should be updated specifically to address federal award requirements. Management Response: While we are confident that adequate controls were in place to ensure that second level approval for the expenditure of grant funds occurred and that it was appropriately documented, we concur with the recommendation. In September 2022, the Chief Financial Officer and Controller again reviewed the record requirements of 45 CFR 75.361. Additionally, our record retention policy has been updated to specifically require all records pertinent to any grant funds, including Federal awards, to be retained for a period of at least seven years from the date of submission of the final expenditure report. This retention period is consistent with our policies governing record retention.