FULTON COUNTY HEALTH CENTERNon-Profit

Assitance Listing Number, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Federal Award Identification Number and Year N/A, 2022 Pass through Entity N/A Direct funded Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding Yes 2021 002 Criteria Per the Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, recipients may choose to apply PRF payments toward lost revenue using one of three options, up to the following amounts: Option i: The difference between actual patient care revenue Option ii: The difference between budgeted (prior to March 27, 2020) and actual patient care revenue Option iii: The amount calculated by any reasonable method of estimating revenue. Condition The Hospital?s controls in place for reporting submissions did not identify that the lost revenue amounts reported in the period 3 portal submission did not consistently follow the Hospital's Option iii methodology. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Refer to context below for additional information. Context The reporting submission for lost revenue did not follow the acceptable options provided by the U.S. Department of Health and Human Services, because the amounts reported by the Hospital were not consistent with its Option iii methodology. Recipients may choose to apply Provider Relief Fund payments toward lost revenue using one of three options: (i) up to the amount of the difference between actual patient care revenue, (ii) up to the amount of the difference between budgeted (if approved prior to March 27, 2020) and actual patient care revenue, or (iii) up to the amount calculated by any reasonable method of estimating revenue. The Hospital used Option iii to calculate lost revenue, but inconsistently applied its methodology and, as a result, reported an incorrect total of lost revenue in 3 of the quarters included in the period 3 submission, resulting in overstated lost revenue of $330,557. If the Hospital had reported amounts that were consistent with its Option iii methodology, it still would have qualified to recognize all PRF payments received during the period. Cause and Effect Appropriate review of the reporting submission was not completed to ensure the report followed the required guidelines and the Hospital's methodologies. As a result, the report submitted was inaccurate. Recommendation We recommend the Hospital implement controls, including levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan Let it be known that if the overstated lost revenue amount from the period 3 submission were to be disallowed by the U.S. Department of Health and Human Services, the unused lost revenue after the overstatement is corrected more than offsets the disallowed amount. The issue was corrected in the period 4 submission.

Assistance Listing Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund (PRF) Federal Award Identification Number and Year - N/A, 2021 Pass through Entity - N/A - Direct funded Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, allowable expenses paid with general and targeted PRF distributions may be reported as a use of PRF funds. Condition - The Hospital's controls in place for reporting submissions did not identify that guidelines were not followed related to the definition of health care expenses. Questioned Costs - $60,741 Identification of How Questioned Costs Were Computed - N/A Refer to context below for additional information. Context - The reporting submission for health care expenses did not follow the guidelines published by the U.S. Department of Health and Human Services (HHS). Per HHS, to be considered an allowable expense under the PRF, the expense must be used to prevent, prepare for, and respond to the coronavirus. In the health care expenses reported, the Hospital included ineligible expenses based on the terms published by HHS. If the Hospital had not included the questioned costs, it still would have qualified to recognize all PRF payments received in periods 1 and 2. Cause and Effect - Appropriate review of the expenses reported was not completed to ensure that only eligible expenses were charged to the award. As a result, the report submitted was inaccurate, but the schedule of expenditures of federal awards was not impacted. Recommendation - We recommend the Hospital implement controls, including levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Corrective Action Plan - Let it be known that if this expense finding were to be disallowed by the U.S. Department of Health and Human Services, the carryforward of other COVID 19 expenses would more than offset the disallowed amount. Period 2 unreimbursed expenses will be adjusted in the HHS PRF Reporting Portal to reflect this audit finding. The Hospital will review its process surrounding the reporting of health care expenses and will implement additional levels of review to prevent this issue from recurring.

Assitance Listing Number, Federal Agency, and Program Name - 93.498, U.S. Department of Health and Human Services, COVID 19: Provider Relief Fund (PRF) Federal Award Identification Number and Year - N/A, 2021 Pass through Entity - N/A - Direct funded Finding Type - Material weakness Repeat Finding - No Criteria - Per the Provider Relief Fund General and Targeted Distribution Post Payment Notice of Reporting Requirements dated June 11, 2021, recipients may choose to apply PRF payments toward lost revenue using one of three options, up to the following amounts: Option i: The difference between actual patient care revenue Option ii: The difference between budgeted (prior to March 27, 2020) and actual patient care revenue Option iii: The amount calculated by any reasonable method of estimating revenue Condition - The Hospital?s controls in place for reporting submissions did not identify that guidelines were not followed related to the lost revenue calculations. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - Refer to context below for additional information. Context - The reporting submission for lost revenue did not follow the acceptable options provided by the U.S. Department of Health and Human Services. Recipients may choose to apply Provider Relief Fund payments toward lost revenue using one of three options: (i) up to the amount of the difference between actual patient care revenue, (ii) up to the amount of the difference between budgeted (if approved prior to March 27, 2020) and actual patient care revenue, or (iii) up to the amount calculated by any reasonable method of estimating revenue. The Hospital used option iii to calculate lost revenue but reported an incorrect total of lost revenue in two of the quarters included in the submission. If the Hospital had reported the correct amounts, it still would have qualified to recognize all PRF payments received in periods 1 and 2. Cause and Effect - Appropriate review of the reporting submission was not completed to ensure the report followed the required guidelines. As a result, the report submitted was inaccurate. Recommendation - We recommend the Hospital implement controls, including levels of review, to ensure reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Planned Corrective Actions - Let it be known that if this lost revenue finding were to be disallowed by the U.S. Department of Health and Human Services, the carryforward of lost revenue from period 1 would more than offset the disallowed amount. Period 2 lost revenue carryforward will be adjusted in the HHS PRF Reporting Portal to reflect this audit finding. The Hospital will review its process surrounding the reporting of lost revenue and will implement additional levels of review to prevent this issue from recurring.