ST. VINCENT CHARITY MEDICAL CENTER AND SUBSIDIARIESNon-Profit

2022-001 ALN, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID-19: Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds (PRF), the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS October 2022, post- payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Condition - The System had a control to review the reporting information under this award, however, the control was ineffective and resulted in incorrect determination of lost revenue reported in required portal submission of such information. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - Lost revenue reported in the PRF portal revealed an overstatement of approximately $5.1 million of lost revenue reported for Period 4. One of the System's subsidiaries, St. Vincent Medical Group, received targeted distributions and reported their respective lost revenue at both the subsidiary and parent level. The aggregate lost revenue reported should have been approximately $18,000 in comparison to $5,100,000 reported. Cause and Effect - The System designed controls related to identification of allowable lost revenue to be entered into the portal for submission to HHS, which included a review of the final lost revenue calculation; however, the review process did not effectively identify lost revenue for targeted distributions that was reported on St. Vincent Medical Group's portal submission and therefore should have been deducted from the amount of lost revenue that was reported on the System portal submission. The failure to have an effective control in place caused the System to overstate the amount of the actual lost revenue available for use in the Period 4 portal submissions. Recommendation - We recommend that the review process include specific procedures to ensure that lost revenue amounts have not been included more than once and that the lost revenue reported in the portal submission follows the guidance provided by the HHS. Further, we recommend that the lost revenue calculation be updated in the next available portal submission. Views of Responsible Officials and Corrective Action Plan - Chief Financial Officer will ensure that all guidance available for PRF reporting is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions.