Meadville Medical CenterNon-Profit

WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing No. 10.557 U.S. Department of Agriculture Criteria or Specific Requirement – Procurement (45 CFR 200.318-200.326) Condition - The Health System, prior to fiscal year 2025, did not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. In addition, the Health System entered into various professional services contracts for marketing, advertising, and information dissemination that do not exceed the simplified acquisition threshold and are considered micro-purchases, but did not maintain appropriate documentation to document the price reasonableness based on research, experience, and purchase history to support its procurement decisions. Questioned Costs - None Context - We tested one out of a total of four contracts that were considered micro-purchases. The sample was not intended to be, and was not, a statistically valid sample. During our testing of procurement requirements, the two vendor contracts tested over the micro-purchase threshold did not have appropriate documentation to evidence the basis of vendor selection (documentation of the price reasonableness based on research, experience, and purchase history). Effect - Micro-purchases were made without appropriate documentation to comply with Uniform Guidance requirements. Cause - The Health System did not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. Adequate supporting documentation on the procurements were not obtained or maintained within vendor files and vendor contracts do not contain the necessary contract provision and language required by the Uniform Guidance. Repeat Finding - Yes Recommendation - We recommend the Health System revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions. We also recommend the Organization perform a comprehensive review of its procurement policy and ensure that it is in compliance and in-line with the procurement requirements of the Uniform Guidance. Views of responsible officials and planned corrective actions – The Organization has developed and implemented a policy and checklist to maintain written documentation of vendor selection and procurement process, along with the review and approval process required under the Uniform Guidance requirements.

WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing No. 10.557 U.S. Department of Agriculture Criteria or Specific Requirement – Procurement (45 CFR 200.318-200.326) Condition - The Health System entered into various professional services contracts for marketing, advertising, and information dissemination that do not exceed the simplified acquisition threshold and are considered micro-purchase awards but did not maintain appropriate documentation to document the price reasonableness based on research, experience, and purchase history to support its procurement decisions. Questioned Costs - None Context - We tested two out of a total of seven contracts that were considered micro-purchases. The sample was not intended to be, and was not, a statistically valid sample. During our testing of procurement requirements, the two vendor contracts tested over the micro-purchase threshold did not have appropriate documentation to evidence the basis of vendor selection (documentation of the price reasonableness based on research, experience, and purchase history). Effect - Micro-purchases were made without appropriate documentation to comply with Uniform Guidance requirements. Cause - The Organization does not have a comprehensive procurement policy that is in line with Uniform Guidance requirements. Adequate supporting documentation on the procurements were not obtained or maintained within vendor files and vendor contracts do not contain the necessary contract provision and language required by the Uniform Guidance. Repeat Finding - No Recommendation - We recommend the Health System revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions. We also recommend the Organization perform a comprehensive review of its procurement policy and ensure that it is in compliance and in-line with the procurement requirements of the Uniform Guidance.

COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Assistance Listing Number 93.498 U.S. Department of Health and Human Services Criteria or Specific Requirement ? Reporting (45 CFR 75.42) and Activities Allowed/Unallowed and Allowable Costs/Cost Principles (Pub. L No 116-136, 134 Stat. 563 and Pub L. No 116-139, 134 Stat. 622 and 623) Condition ? The Health System filed two Provider Relief Fund reports during Period 1 reporting. For one of the reports filed, the Health System could not support the quarterly patient care revenues reported the U.S. Department of Health and Human Services (DHHS). The other report filed by the Health System utilized Option ii to report lost revenues. Under Option ii lost revenues are determined to be the difference between budgeted and actual patient care revenues; however, this option requires the budget for the entire period of performance to be approved prior to March 27, 2020. For the reporting entity that filed this report, the budget approved prior to that date did not apply to the entire period of performance. In addition, amounts reported as budgeted patient care revenues for the first quarter of 2020 did not match the approved budget amounts. Questioned Costs ? Unknown Context ? The Provider Relief Fund reports for Period 1 were obtained and it was determined that the Health System could not support quarterly amounts reported as patient care revenues. In addition, it was determined that a separate reporting entity utilized Option ii to report lost revenues although the reporting entity?s budget was not approved for the full period of performance prior to March 27, 2020. The reporting entity only approved a budget through June 30, 2020, before March 27, 2020. Effect ? The Health System?s reporting of lost revenues to DHHS for Period 1 was not prepared in accordance with the requirements determined by DHHS. In addition, the lost revenues were not properly supported by utilizing Option ii. Cause ? Management of the Health System did not fully understand the various methods and requirements of each of the three options to determine and report lost revenues. Identification as a Repeat Finding ? Not applicable Recommendation ? Management should review the reporting requirements of each of the three options allowed to report lost revenues. In addition, management should consider resubmission of the Period 1 report to DHHS utilizing either Option i or Option iii and should utilize this method to report lost revenues for any future periods. Management should ensure all reported data is accurate and reconciles to the financial statements. Views of Responsible Officials and Planned Corrective Actions ? We have identified the issues/errors associated with this finding. We are in the process of correcting the errors associated with the entities for which the portal is now open. For entities that are not open, we will correct as soon as they become open. Going forward, we have put a review process in place to try and avoid future errors.