THE BELLEVUE HOSPITAL AND SUBSIDIARIESNon-Profit

Assistance Listing Number, Federal Agency, and Program Name 97.036, U.S. Department of Homeland Security Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year 4507 2022 Pass through Entity Ohio Office of Emergency Management Services Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria According to 2 CFR § 200.403(f), which outlines factors affecting the allowability of costs under federal awards, costs must not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. This provision is intended to prevent duplication of federal funding and ensure that each program bears only its fair share of costs. Condition Costs charged to ALN 97.036 Disaster Grants Public Assistance were also charged to ALN 93.498, U.S. Department of Health and Human Services Provider Relief Fund in a prior fiscal year, as reported in the Period 1 submission to the Provider Relief Fund portal. Questioned Costs $275,952 Identification of How Questioned Costs Were Computed Questioned costs represent all expenditures reported on the schedule of expenditures of federal awards (SEFA) for costs charged to ALN 97.036 Disaster Grants Public Assistance. Context All expenditures reported as ALN 97.036 expenditures on the December 31, 2022 SEFA, which are amounts obligated during the year ended December 31, 2022 based on the application submitted by the Hospital, were also reported as expenditures on the Period 1 PRF portal submission. Cause and Effect Appropriate and effective review of the request for funding submitted under ALN 97.036 was not completed to ensure that the costs were not reimbursed by another funding source. As a result, all costs charged to ALN 97.036 were already reimbursed under ALN 93.498. Recommendation We recommend the Hospital implement controls, including levels of review, to ensure that all costs submitted on funding applications were not already reimbursed under a separate grant. Views of Responsible Officials and Corrective Action Plan Management agrees and has revised existing internal control processes and policies to implement review and approval procedures to ensure expenditures submitted were not already reimbursed under a separate grant.

ALN, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services: Provider Relief Fund. Federal Award Identification Number and Year - N/A, 2020. Pass-through Entity - N/A. Finding Type - Material weakness and material noncompliance with laws and regulations. Repeat Finding - No. Criteria - The U.S. Department of Health and Human Services (HHS) requires the nonfederal entity to report lost revenue and expenses incurred in order to support that funding received has been used for allowable activities. HHS has provided specific guidance in the June 11, 2021 Post-Payment Notice on how to complete the required reporting of lost revenue and qualifying expenses in the reporting portal. Condition - The Hospital's reporting submissions did not follow the HHS guidelines related to the reporting of lost revenue for the reporting period. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Certain quarterly revenue amounts reported in the in the Period 1 portal submission for Total Revenue/Net Charges from Patient Care 2019 Actuals and Total Revenue/Net Charges from Patient Care 2020 Actuals did not follow the guidance prescribed by HHS. The Period 1 reporting submission quarterly revenue amounts were improperly submitted (reported) into the reporting portal due to clerical error. Cause and Effect - Appropriate review of the reporting submission was not completed to ensure the report followed the required guidelines. As a result, the revenue for the quarters were improperly stated within the Period 1 reporting submission by understating lost revenues by $284,003. Recommendation - We recommend the Hospital implement controls, including levels of review, to ensure reports are completed and submitted in accordance with the HHS guidelines. Views of Responsible Officials and Corrective Action Plan - When incorrect data entry was discovered, Case #00045679 was opened with the HRSA PRB case management team. An update was not necessary because PRF repayments was not required.

ALN, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services: Provider Relief Fund Federal Award Identification Number and Year - N/A, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - While 45 CFR 75 Subpart E - Cost Principles do not apply to the Provider Relief Fund (PRF), charges to PRF must necessary, reasonable, accorded consistent treatment, and conform to limitations and exclusions of the terms and conditions of the awards. In order to comply with the program?s regulations, non-federal entities must establish and maintain effective internal controls over the federal award, as described in 2 CFR 200.303(a). Condition - The Hospital's amount of allowable costs related to the qualifying expenses submitted for reporting period 1 were improperly stated at incorrect amounts and duplicate amounts. Questioned Costs - $0 Identification of How Questioned Costs Were Computed - N/A Context - The Period 1 reporting submission for qualifying expenses did not follow the guidelines provided by the HHS. The Period 1 reporting submission improperly included duplicate expenses and expenses reported at incorrect amounts. The client evaluated the expenses and determined $877,094 of qualifying expenses that were unallowable in the period 1 HHS portal submission. These unallowable expenditures were covered by the excess lost revenue as reported within the period 1 HHS portal submission. Cause and Effect - Appropriate review of the qualifying expense reports generated from the accounting system was not completed to ensure the report followed the required guidelines. As a result, the qualifying expenses were overstated within the Period 1 reporting submission. Recommendation - We recommend the Hospital implement controls, including levels of review, to ensure the proper invoice amounts are utilized in determining the total qualifying expenses submitted are in accordance with the HHS guidelines. Views of Responsible Officials and Planned Corrective Actions - When duplicate amounts were discovered, the spreadsheets were consolidated, reconciled, and duplicate entries removed.