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2023-001 Department of Health and Human Services Federal Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #463364672, Period 4 TIN #410721640, Period 4 TIN #450275011, and Period 5 TIN #272608086 Department of Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grants Cluster Preparation of Consolidated Schedule of Expenditures of Federal Awards Significant Deficiency in Internal Control over Compliance - Other Criteria: Proper controls over financial reporting include the ability to prepare the consolidated schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Condition: The Organization does not have an internal control system designed to provide for a complete and accurate consolidated schedule of expenditures of federal awards being audited. Cause: Auditor assistance with the preparation of the Schedule is not unusual, as the Schedule has unique and specialized requirements and preparation is only required when the Organization meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Organization would not be able to draft a Schedule that is correct without the assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: Yes, Finding 2022-001. Recommendation: We recommend management be aware of the financial reporting requirements relating to the Organization’s consolidated schedule of expenditures of federal awards and implement internal controls that consist of a preparer and reviewer. Views of Responsible Officials: Management agrees with the finding.

2023-002 Department of Health and Human Services Federal Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #463364672, Period 4 TIN #410721640, Period 4 TIN #450275011, and Period 5 TIN #272608086 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.33(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award. The Organization is required to submit an accurate report to HHS for each filing period that funds were received. Condition: The Organization claimed lost revenues attributable to coronavirus in which the resident revenue calculation did not agree to the HHS special report for two key line items. Cause: The Organization had a resident revenue calculation error of $269,085 on the HHS special report with no impact to the actual lost revenues (i.e. lost revenue claimed was accurate on the HHS special report but key line items were misstated). Effect: While the calculation error did not provide a difference in total between the lost revenues utilized on the HHS special report and the lost revenue calculation, the Organization’s reported quarterly resident revenues were inaccurate. This calculation error also indicated there is a lack of policies governing the review and approval of the lost revenue calculation to the HHS special report. Questioned Costs: None reported. Context: There were 66 lost revenue key line items tested on which two key line items contained errors which totaled $269,085 (resident revenue was understated for both quarters). The errors had no impact on the amount of lost revenue as the two quarters impacted did not result in any lost revenue. Repeat Finding from Prior Years: Yes, Finding 2022-003. Recommendation: We recommend that the Organization enhance internal control policies to ensure the HHS special report is supported by accurate revenue calculations. This would include implementing a secondary review and approval over the lost revenue calculation. Views of Responsible Officials: Management agrees with the finding.

2022-001 Department of Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grants Cluster Preparation of Consolidated Schedule of Expenditures of Federal Awards Material Weakness in Internal Control Over Compliance - Other Criteria: Proper controls over financial reporting include the ability to prepare the consolidated schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Condition: The Organization does not have an internal control system designed to provide for a complete and accurate consolidated schedule of expenditures of federal awards being audited. Cause: Auditor assistance with preparation of the Schedule is not unusual, as the Schedule has unique and specialized requirements and preparation is only required with the Organization meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Organization would not be able to draft a Schedule that is correct without assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: Yes Recommendation: We recommend management be aware of the financial reporting requirements relating to the Organization?s consolidated schedule of expenditures of federal awards and internal controls that impact financial reporting. Views of Responsible Officials: Management agrees with the finding.

2022-002 Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 2 TIN #463364672, Period 2 TIN #272608086, Period 2 TIN #410721640, Period 2 and Period 3 TIN #450275011, Period 2 and Period 3 TIN #204531061 Activities Allowed or Unallowed and Allowable Costs/Costs Principles Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: There was no formal documentation of review and approval for the final expenditure listing. There was also no formal review over tracking of other sources of funding to ensure that expenses claimed for the program were not claimed by other funding sources. The Organization?s calculation of lost revenue claimed under the federal program as an allowable cost contained no formal review or approval by a separate individual outside of the preparer. Cause: The Organization did not have an adequate internal control policy in place to ensure review and approval of direct COVID expenses, tracking of other funding sources, or calculation of lost revenue was documented. Effect: The lack of adequate policies governing review and approval increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: Detail testing was performed over payroll and expenses for activities allowed and unallowable and allowable cost/cost principles. In addition, the lost revenue calculation for all applicable quarters was tested. Repeat Finding from Prior Years: Yes Recommendation: We recommend that the Organization enhance internal control policies to ensure that formal documentation of review and approval is present. Views of Responsible Officials: Management agrees with the finding

2022-003 Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 2 TIN #463364672, Period 2 TIN #272608086, Period 2 TIN #410721640, Period 2 and Period 3 TIN #450275011, Period 2 and Period 3 TIN #204531061 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.33(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award. The Organization is required to submit an accurate report to HHS for each filing period of funds were received. Condition: The Organization claimed lost revenues attributable to coronavirus in which the final lost revenue calculation did not tie to the HHS Report. Cause: The Organization had a lost revenue calculation error of $141,573 on the HHS special report causing a difference to the actual lost revenues (i.e. there were more lost revenues reported on the HHS special report). Effect: While the calculation error provided a difference between the lost revenues on the HHS special report and the lost revenue calculation, the Organization had excess lost revenues available to be applied to future periods. This calculation error also indicated there is a lack of policies governing the review and approval of the lost revenue calculation to the HHS special report. Questioned Costs: None reported. Context: The HHS special reports included total lost revenue calculation errors of $141,573. For the TINs that had lost revenue calculation errors, excess amounts of lost revenues consist of: TIN #463364672, excess lost revenues of $885,328 (error had no impact on lost revenue amount calculated); TIN #410721640, excess lost revenues of $3,189,219 (after error ? error decreased amount of excess lost revenue); TIN #272608086, excess lost revenues of $3,236,647 (after error ? error decreased amount of excess lost revenues);TIN #450275011, excess lost revenues of $700,778 (after error ? error increased amount of excess lost revenues); and TIN #204531061, excess lost revenues of $1,038,908 (error in Report 2, corrected on Report 3). Repeat Finding from Prior Years: No Recommendation: We recommend that the Organization enhance internal control policies to ensure the HHS special report is supported by accurate lost revenue calculations. This would include implementing a secondary review and approval over the lost revenue calculation. Views of Responsible Officials: Management agrees with the finding.

2021-001 Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year ? Period 1 TIN #463364672, Period 1 TIN #272608086, Period 1 TIN #410721640, Period 1 TIN #450275011 Preparation of Consolidated Schedule of Expenditures of Federal Awards Material Weakness in Internal Control Over Compliance - Other Criteria: Proper controls over financial reporting include the ability to prepare the consolidated schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Condition: The Organization does not have an internal control system designed to provide for a complete and accurate consolidated schedule of expenditures of federal awards being audited. We were requested to draft the Schedule. Cause: Auditor assistance with preparation of the Schedule is not unusual, as the Schedule has unique and specialized requirements and preparation is only required with the Organization meets a specified threshold of federal expenditures. Effect: There is a reasonable possibility that the Organization would not be able to draft a Schedule that is correct without assistance of the auditors. Questioned Costs: None reported. Context: Sampling was not used. Repeat Finding from Prior Years: No Recommendation: We recommend management be aware of the financial reporting requirements relating to the Organization?s consolidated schedule of expenditures of federal awards and internal controls that impact financial reporting. Views of Responsible Officials: Management agrees with the finding.

2021-002 Department of Health and Human Services Federal Assistance Listing/CFDA #93.498 COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year ? Period 1 TIN #463364672, Period 1 TIN #272608086, Period 1 TIN #410721640, Period 1 TIN #450275011 Activities Allowed or Unallowed and Allowable Costs/Cost Principles, and Reporting Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: There was no formal documentation of review and approval for the calculations of incremental expenses. There was also no formal review over tracking of other sources of funding to ensure that expenses claimed for the program were not claimed by other funding sources. The Organization?s calculation of lost revenue claimed under the federal program as an allowable cost contained no formal review or approval by a separate individual outside of the preparer. In addition, there was no evidence retained that the Organization?s special reports submitted to the Department of Health and Human Services for Period 1 was reviewed and approved by a separate individual outside of the preparer. Cause: The Organization did not have an adequate internal control policy in place to ensure review and approval of direct and incremental COVID expenses, tracking of other funding sources, calculation of lost revenue, or preparation HHS Period 1 reporting was documented. Effect: The lack of adequate policies governing review and approval increases the risk that employees participating in the federal award administration may not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. Context/Sampling: Summary level testing was performed over incentive pay and incremental wage expenses for activities allowed and unallowable and allowable cost/cost principles. In addition, the lost revenue calculation for all applicable quarters was tested, and key line items were tested on the Period 1 Department of Health and Human Services special report. Repeat Finding from Prior Years: No Recommendation: We recommend that the Organization enhance internal control policies to ensure that formal documentation of review and approval is present. Views of Responsible Officials: Management agrees with the finding.