ELLA E. M. BROWN CHARITABLE CIRCLE D/B/A OAKLAWN HOSPITALNon-Profit

Assistance Listing Number, Federal Agency, and Program Name 93.498, U.S. Department of Health and Human Services (HHS), COVID 19 Provider Relief Fund 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 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 towards lost revenues using one of three options, up to the amount: Option i: of the difference between actual patient care revenues; Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues; or Option iii: calculated by any reasonable methodology of estimating revenues. Condition The Hospital's controls in place for reporting submissions did not identify that General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Hospital's Period 1 and Period 2 reporting submissions for lost revenue did not follow the acceptable options provided by HHS. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Refer to context below for additional information. Context The single audit for the Hospital included two portal submissions (Period 1 and Period 2). The Period 1 and Period 2 reporting submissions for lost revenue did not follow the acceptable options provided by the HHS, as noted in the criteria above. Oaklawn Hospital had reported to HHS that they used option ii to calculate their lost revenue included in their portal submissions. However, the budgeted amounts for patient care revenue relating to the second through fourth quarters of calendar year 2021 were not approved prior to March 27, 2020; therefore, option ii was not allowable. The Hospital should have selected option iii in its portal submissions. Finally, by not selecting option iii, Oaklawn Hospital omitted required information related to the reason for selecting option iii in their submissions. Cause and Effect Appropriate review of the reporting submissions was not completed to ensure the reports followed required guidelines. As a result, the Hospital submitted incorrect reports, attesting to using an incorrect methodology for reporting lost revenues. Additionally, because the Hospital attested to using option ii, they did not provide the additional information to HHS that would have been required if option iii would have been selected correctly. This additional information includes an explanation for the reason the Hospital used option iii for reporting lost revenue. Recommendation We recommend that the Hospital implement controls, including levels of review, to ensure that reports are completed and submitted in accordance with the guidelines established by HHS. Views of Responsible Officials and Planned Corrective Actions The Hospital will review its processes surrounding the methodologies used to report lost revenue and will implement additional levels of review to ensure that the proper lost revenue methodology is used in future reporting periods.