Saint Anthony Health Ministries and Subsidiaries

Finding 2024-006: Cash Management – Significant Deficiency Information on the federal program: Federal program is American Rescue Plan Act - Violence Prevention and Reduction Grant Portfolio from the U.S. Department of Treasury passed through the Justice Advisory Council. Criteria: Under 2 CFR 200.305, non-federal entities must minimize the time between drawing federal funds and disbursing those funds for grant-related expenditures. For cost-reimbursement grants, entities should only request reimbursement for costs that have already been incurred. Condition: The Organization drew down federal funds under the American Rescue Plan Act (ALN 21.027) before incurring the related expenditures. Draw request amounts were based on estimated costs instead of actual, supported expenditures. Management indicated this occurred due to an oversight that resulted in estimated draw requests being submitted. Cause: The Organization did not have adequate procedures in place to ensure draw requests were based solely on actual expenditures incurred under the grant Effect: Drawing funds prior to incurring allowable costs is noncompliant with federal cash management requirements and may result in the federal government or the pass-through entity requiring repayment of improperly drawn funds. Additionally, early draws increase the risk that federal funds may be used for non-allowable or unsupported purposes. Questioned Costs: None. Context: During our testing of drawdown activity for the Justice Advisory Council (JAC) pass-through award, we identified instances in which the Organization submitted draw requests based on estimated expenditures rather than actual incurred costs. The sampled drawdown was requested before the underlying expenditures occurred, indicating that the Organization’s draw procedures allowed submissions that were not tied to actual costs at the time of the request. Identification as a Repeat Finding: 2023-007 Recommendation: We recommend that management implement procedures to ensure that all draw requests are based strictly on incurred, supported expenditures. Draw requests should reflect the actual expenditures for the reporting period, and an individual should be assigned responsibility for monitoring the timing and accuracy of draw submissions. Views of responsible officials and planned corrective actions: Subsequent to this grant commencing, the Organization hired a new grant and partnership specialist. This specialist reviews all draws to ensure that the draw is for reimbursement for actual expenditure and not estimated expenditure. Reports and draws are also reviewed by the vice president of finance.

Finding 2024-007: Document Retention – Material Weakness Information on the federal program: Federal program is American Rescue Plan Act - Violence Prevention and Reduction Grant Portfolio from the U.S. Department of Treasury passed through the Justice Advisory Council. Criteria: Under 2 CFR 200.334, non-federal entities must retain financial and programmatic records, supporting documentation, statistical records, and all other records pertinent to a federal award for the required retention period. Records must be maintained in a manner that allows them to be readily accessible for audit and monitoring purposes. Effective internal controls include maintaining complete, organized, and retrievable documentation to support financial reporting and compliance. Condition: The Organization does not have an effective document retention process or internal controls to ensure that key financial records are consistently preserved, organized, and readily retrievable. Supporting documentation such as invoices, contracts, reconciliations, journal entry support, and grant documentation was frequently incomplete, missing, or delayed in being provided. These gaps resulted in incomplete audit trails and limited management’s ability to demonstrate the completeness, accuracy, and validity of financial information. Cause: The Organization has not designed, implemented, or maintained adequate document retention procedures, nor assigned responsibility to ensure consistent storage, organization, and retrieval of supporting financial documentation. Effect: Without complete and accessible supporting documentation, the Organization cannot substantiate recorded amounts, validate the occurrence or completeness of transactions, or demonstrate the functioning of key internal controls. This increases the risk that material misstatements in the financial statements or noncompliance with federal requirements may not be prevented or detected in a timely manner. Questioned Costs: None. Context: During the audit, we requested various supporting documents needed to verify financial transactions, account balances, and management representations for the period under audit. In multiple instances, the Organization was unable to locate or provide the requested documentation in a timely manner. These difficulties occurred across several financial areas, including invoices, reconciliations, journal entry support, grant-related documentation, and valuation records, indicating that document retention challenges were pervasive rather than isolated to one type of record. Identification as a Repeat Finding: 2023-008 Recommendation: We recommend that management implement a comprehensive document retention and recordkeeping policy that establishes standardized retention requirements for all key financial documentation, including invoices, contracts, reconciliations, journal entries, and grant support. Management should develop procedures for centralized and secure storage, either physical or electronic, to ensure records are properly preserved and readily accessible. Additionally, periodic monitoring should be performed to confirm compliance with retention procedures, and staff should receive training to reinforce expectations regarding documentation maintenance and timely retrieval. Views of responsible officials and planned corrective actions: Subsequent to this grant commencing, the Organization hired a new grant and partnership specialist. This specialist attaches all relevant support for expenditure to the internal monthly grant reporting and ensures that all expenditures are fully supported by appropriate detail. This detail is on a shared drive with finance and is reviewed by the vice president of finance.

Finding 2024-008: Procurement – Significant Deficiency Information on the federal program: Federal program is American Rescue Plan Act - Violence Prevention and Reduction Grant Portfolio from the U.S. Department of Treasury passed through the Justice Advisory Council. Criteria: Non-federal entities other than states must follow the procurement standards set out in 2 CFR sections 200.318 through 200.327. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statues and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization does not maintain a formal procurement policy and procedures that meets the requirements of the Uniform Guidance, including procedures addressing allowable costs exceeding the small purchase threshold. The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance. Cause: The Organization has not implemented a formal procurement policy and procedures that meets the requirements for the Uniform Guidance. Effect: The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance requirements. Questioned Costs: None. Context: As part of our testing over procurement standards under the Uniform Guidance, we requested documentation supporting the Organization’s procurement policies and procedures, including thresholds, required competition, documentation requirements, and approval processes. The Organization was unable to provide a formalized or adopted procurement policy. Additionally, procurement documentation reviewed during the audit indicated that purchases were made without evidence of compliance with federal procurement standards, confirming that the deficiency was systemic and not limited to a single transaction or department. Identification as a Repeat Finding: 2023-009 Recommendation: We recommend that management implement a formal procurement policy and procedures that meets the requirements of the Uniform Guidance. Views of responsible officials and planned corrective actions: While Saint Anthony Hospital has a procurement policy in place, we need to order computers within a certain time frame in order to secure funds from the grant and utilize our main supplier. Thus, we did not get more than 1 quote for the computers. The procurement policy as well as all policies are reviewed every three years to comply with Joint Commission Standards. Saint Anthony will review its existing procurement policy to ensure that all elements required by the Uniform Guidance are incorporated. The review was completed on March 28, 2025.

Finding 2023-006: Cash Management – Significant Deficiency Information on the federal program: Federal program is Crime Victim Assistance from the U.S. Department of Justice passed through the Criminal Justice Information Authority. Criteria: Under 2 CFR 200.305, non-federal entities must minimize the time between drawing federal funds and disbursing those funds for grant-related expenditures. For cost-reimbursement grants, entities should only request reimbursement for costs that have already been incurred. Condition: The Organization drew down federal funds before incurring the related expenditures. Draw request amounts were based on estimated costs instead of actual, supported expenditures. Management indicated this occurred due to an oversight that resulted in estimated draw requests being submitted. Cause: The Organization did not have adequate procedures in place to ensure draw requests were based solely on actual expenditures incurred under the grant. Effect: Drawing funds prior to incurring allowable costs is noncompliant with federal cash management requirements and may result in the federal government or the pass-through entity requiring repayment of improperly drawn funds. Additionally, early draws increase the risk that federal funds may be used for non-allowable or unsupported purposes. Questioned Costs: None. Context: During our testing of drawdown activity, we identified instances in which the Organization submitted draw requests based on estimated expenditures rather than actual incurred costs. The sampled drawdown was requested before the underlying expenditures occurred, indicating that the Organization’s draw procedures allowed submissions that were not tied to actual costs at the time of the request. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management implement procedures to ensure that all draw requests are based strictly on incurred, supported expenditures. Draw requests should reflect the actual expenditures for the reporting period, and an individual should be assigned responsibility for monitoring the timing and accuracy of draw submissions. Views of responsible officials and planned corrective actions: Subsequent to this grant commencing, the Organization hired a new grant and partnership specialist. This specialist reviews all draws to ensure that the draw is for reimbursement for actual expenditure and not estimated expenditure. Reports and draws are also reviewed by the vice president of finance.

Finding 2023-007: Document Retention – Material Weakness Information on the federal program: Federal program is Crime Victim Assistance from the U.S. Department of Justice passed through the Criminal Justice Information Authority. Criteria: Under 2 CFR 200.334, non-federal entities must retain financial and programmatic records, supporting documentation, statistical records, and all other records pertinent to a federal award for the required retention period. Records must be maintained in a manner that allows them to be readily accessible for audit and monitoring purposes. Effective internal controls include maintaining complete, organized, and retrievable documentation to support financial reporting and compliance. Condition: The Organization does not have an effective document retention process or internal controls to ensure that key financial records are consistently preserved, organized, and readily retrievable. Supporting documentation such as invoices, contracts, reconciliations, journal entry support, and grant documentation was frequently incomplete, missing, or delayed in being provided. These gaps resulted in incomplete audit trails and limited management’s ability to demonstrate the completeness, accuracy, and validity of financial information. Cause: The Organization has not designed, implemented, or maintained adequate document retention procedures, nor assigned responsibility to ensure consistent storage, organization, and retrieval of supporting financial documentation. Effect: Without complete and accessible supporting documentation, the Organization cannot substantiate recorded amounts, validate the occurrence or completeness of transactions, or demonstrate the functioning of key internal controls. This increases the risk that material misstatements in the financial statements or noncompliance with federal requirements may not be prevented or detected in a timely manner. Questioned Costs: $29,414 Context: During the audit, we requested various supporting documents needed to verify financial transactions, account balances, and management representations for the period under audit. In multiple instances, the Organization was unable to locate or provide the requested documentation in a timely manner. These difficulties occurred across several financial areas, including invoices, reconciliations, journal entry support, grant-related documentation, and valuation records, indicating that document retention challenges were pervasive rather than isolated to one type of record. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management implement a comprehensive document retention and recordkeeping policy that establishes standardized retention requirements for all key financial documentation, including invoices, contracts, reconciliations, journal entries, and grant support. Management should develop procedures for centralized and secure storage, either physical or electronic, to ensure records are properly preserved and readily accessible. Additionally, periodic monitoring should be performed to confirm compliance with retention procedures, and staff should receive training to reinforce expectations regarding documentation maintenance and timely retrieval. Views of responsible officials and planned corrective actions: Subsequent to this grant commencing, the Organization hired a new grant and partnership specialist. This specialist attaches all relevant support for expenditure to the internal monthly grant reporting and ensures that all expenditures are fully supported by appropriate detail. This detail is on a shared drive with finance and is reviewed by the vice president of finance.

Finding 2023-008: Procurement – Significant Deficiency Information on the federal program: Federal program is Crime Victim Assistance from the U.S. Department of Justice passed through the Criminal Justice Information Authority. Criteria: Non-federal entities other than states must follow the procurement standards set out in 2 CFR sections 200.318 through 200.327. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statues and the procurement requirements identified in 2 CFR Part 200. Condition: The Organization does not maintain a formal procurement policy and procedures that meets the requirements of the Uniform Guidance, including procedures addressing allowable costs exceeding the small purchase threshold. The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance. Cause: The Organization has not implemented a formal procurement policy and procedures that meets the requirements for the Uniform Guidance. Effect: The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance requirements. Questioned Costs: None. Context: As part of our testing over procurement standards under the Uniform Guidance, we requested documentation supporting the Organization’s procurement policies and procedures, including thresholds, required competition, documentation requirements, and approval processes. The Organization was unable to provide a formalized or adopted procurement policy. Additionally, procurement documentation reviewed during the audit indicated that purchases were made without evidence of compliance with federal procurement standards, confirming that the deficiency was systemic and not limited to a single transaction or department. Identification as a Repeat Finding: 2022-008 Recommendation: We recommend that management implement a formal procurement policy and procedures that meets the requirements of the Uniform Guidance. Views of responsible officials and planned corrective actions: While Saint Anthony Hospital has a procurement policy in place, we need to order computers within a certain time frame in order to secure funds from the grant and utilize our main supplier. The procurement policy as well as all policies are reviewed every three years to comply with Joint Commission Standards. Saint Anthony will review its existing procurement policy to ensure that all elements required by the Uniform Guidance are incorporated. The review was completed on March 28, 2025.

Finding 2022-005 Segregation of Duties Applicable to all assistance listing numbers and Federal Agencies (and pass-through entities) included on the accompanying Schedule of Expenditures of Federal Awards for the year ended June 30, 2022. Questioned costs: None. Identification as a repeat finding, if applicable: 2021-006 See finding 2022-001.

2022-006 Timely Submission of Data Collection Form and Single Audit Reporting to the Federal Audit Clearinghouse Applicable to all assistance listing numbers and Federal Agencies (and pass-through entities) included on the accompanying Schedule of Expenditures of Federal Awards for the year ended June 30, 2022. Criteria: Under the Uniform Guidance, Section 200.512, Report Submission, the audit must be completed and the data collection form and single audit reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. Condition: The Corporation’s fiscal year 2022 Single Audit package was not submitted to the FAC by the deadline of March 31, 2023. This was the third consecutive fiscal year that this deadline has not been met. Cause: The information was not timely filed because of delays in completing the single audit. Resource constraints within the Corporation’s Finance function, coupled with demands placed on the function as a result of the COVID-19 pandemic and other circumstances, have contributed to these delays. Effect: The data collection form and single audit reporting package were not received by the FAC by the prescribed due date. Questioned costs: None. Identification as a repeat finding, if applicable: 2021-009 Recommendation: We recommend the Corporation continue its efforts to identify appropriate resources and implement the procedures necessary to ensure timely submission of the single audit reporting package. View of responsible officials of the auditee: Management agrees with the finding and recommendation.

2022-007 Maintenance of Documentation of Internal Control Over Compliance U.S. Department of Justice, Passed through Illinois Criminal Justice Information Authority Crime Victim Assistance – Assistance Listing Number 16.575, Pass-through Entity Identifying Number 546-00-1745 Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that documentation to evidence the operation of internal controls, such as supervisory reviews.   Condition: The Corporation did not have sufficient documentation that internal controls were in place and operating effectively for control activities required for assessment of activities allowed or unallowed and for allowable costs/cost principles. The Corporation also did not have sufficient documentation that internal controls were in place and operating effectively for monitoring procedures required for cash management and reporting compliance requirements. Although the Corporation provided documentation supporting the costs reported, there was no formal documentation of the control activities for approval of activities allowed or unallowed and allowable costs/cost principles. Formal documentation of the supervisory review of cash management and supervisory review and approval of the information compiled for the reporting compliance requirement was also unavailable. Cause: The Corporation did not maintain documentation evidencing the operation of specific internal controls. Effect: Lack of properly documented evidence of approval of activities allowed or unallowed and allowable costs/cost principles. Lack of properly documented evidence of supervisory review of cash management and reporting policies and procedures could result in the loss of future funding. Questioned costs: None Identification as a repeat finding, if applicable: 2021-010 Recommendation: We recommend that management reviews current processes, polices, and procedures to ensure that approval of activities allowed or unallowed and approval of allowable costs/cost principles are properly documented. We recommend that management reviews current processes, policies, and procedures to ensure that supervisory review of cash management and reporting compliance requirements are properly documented. View of responsible officials of the auditee: Management agrees with the finding and recommendation.

2022-008 Procurement Policy and Procedures U.S. Department of Justice, Passed through Illinois Criminal Justice Information Authority Crime Victim Assistance – Assistance Listing Number 16.575 Criteria: Non-federal entities other than states must follow the procurement standards set out in 2 CFR sections 200.318 through 200.327. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Corporation does not maintain a formal procurement policy and procedures that meets the requirements of the Uniform Guidance, including procedures addressing allowable costs exceeding the small purchase threshold. The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance requirements. Cause: The Corporation has not implemented a formal procurement policy and procedures that meets the requirements of the Uniform Guidance. Effect: The lack of such a formal policy increases the risk that purchases are made that do not comply with Uniform Guidance requirements. Questioned costs: None Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that the Corporation implement a formal procurement policy and procedures that meets the requirements of the Uniform Guidance. View of responsible officials of the auditee: Management agrees with the finding and recommendation.

Finding 2021-006 Segregation of Duties Applicable to all assistance listing numbers and Federal Agencies (and pass-through entities) included on the accompanying Schedule of Expenditures of Federal Awards for the year ended June 30, 2021. Questioned costs: None. Identification as a repeat finding, if applicable: 2020-007 See finding 2021-002.

Finding 2021-007 Accounting for Liabilities Applicable to all assistance listing numbers and Federal Agencies (and pass-through entities) included on the accompanying Schedule of Expenditures of Federal Awards for the year ended June 30, 2021. Questioned costs: None. Identification as a repeat finding, if applicable: This is not a repeat finding. See finding 2021-003

Finding 2021-008 Improper Preparation of Schedule of Expenditures of Federal Awards U.S. Department of Health and Human Services COVID-19: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund – Assistance Listing Number 93.461 Criteria: In accordance with 2 CFR 200 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Condition: The Corporation’s SEFA for the year ended June 30, 2021, was initially prepared without federal expenditures totaling $1,222,859 for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund, Assistance Listing number 93.461. Cause: The federal program expenditures for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund, Assistance Listing number 93.461, were omitted from the SEFA due to an oversight in the preparation of the SEFA. Effect: Improper reporting of federal expenditures resulted in a material error on the SEFA leading to inaccurate major program determination by the auditors. In this instance, the error did result in the identification of an additional major program. Questioned costs: None. Identification as a repeat finding, if applicable: 2020-005 Recommendation: We recommend the Corporation enhance the process and internal controls around the timely identification of federal awards and preparation of the SEFA to ensure accuracy and completeness of the SEFA. View of responsible officials of the auditee: Management agrees with the finding and recommendation.

2021-009 Timely Submission of Data Collection Form and Single Audit Reporting to the Federal Audit Clearinghouse Applicable to all assistance listing numbers and Federal Agencies (and pass-through entities) included on the accompanying Schedule of Expenditures of Federal Awards for the year ended June 30, 2021. Criteria: Under the Uniform Guidance, Section 200.512, Report Submission, the audit must be completed and the data collection form and single audit reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. This deadline would have been March 31, 2022, for the Corporation’s reporting for the year ended June 30, 2021. However, because the Corporation received Provider Relief Fund distributions, this deadline was extended by six months to September 30, 2022. Condition: The Corporation’s fiscal year 2021 Single Audit package was not submitted to the FAC by the extended deadline of September 30, 2022. Cause: The information was not timely filed because of delays in completing the single audit. Effect: The data collection form and single audit reporting package were not received by the FAC by the prescribed due date. Questioned costs: None. Identification as a repeat finding, if applicable: 2020-003 Recommendation: We recommend that management ensure that these reporting requirements are timely completed. View of responsible officials of the auditee: Management agrees with the finding and recommendation.

2021-010 Maintenance of Documentation of Internal Control Over Compliance U.S. Department of Justice, Passed through Illinois Criminal Justice Information Authority Crime Victim Assistance – Assistance Listing Number 16.575 U.S. Department of Health and Human Services COVID-19, Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution – Assistance Listing Number 93.498 Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that documentation to evidence the operation of the controls, such as supervisory reviews. Condition: The Corporation did not have sufficient documentation that internal controls were in place and operating effectively for control activities required for assessment of activities allowed or unallowed and for allowable costs/cost principles. The Corporation also did not have sufficient documentation that internal controls were in place and operating effectively for monitoring procedures required for cash management and reporting compliance requirements. Although the Corporation provided documentation supporting the costs reported, there was no formal documentation of the control activities for approval of activities allowed or unallowed and allowable costs/cost principles. Formal documentation of the supervisory review of cash management and supervisory review and approval of the information compiled for the reporting compliance requirement was also unavailable. Cause: The Corporation did not maintain documentation evidencing the operation of specific internal controls. Effect: Lack of properly documented evidence of approval of activities allowed or unallowed and allowable costs/cost principles. Lack of properly documented evidence of supervisory review of cash management and reporting policies and procedures could result in the loss of future funding. Questioned costs: None Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that management review current processes, polices, and procedures to ensure that approval of activities allowed or unallowed and approval of allowable costs/cost principles are properly documented. We recommend that management review current processes, policies, and procedures to ensure that supervisory review of cash management and reporting compliance requirements are properly documented. View of responsible officials of the auditee: Management agrees with the finding and recommendation.

22020-003 Timely Submission of Data Collection Form and Single Audit Reporting to the Federal Audit Clearinghouse (FAC)Finding: The Corporation did not file its data collection form and single audit reporting package for the year ended June 30, 2020, by the extended deadline of September 30, 2021.

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