Bothwell Regional Health CenterNon-Profit

U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri ALN 93.680 - Medical Student Education PTE Federal Award No: C00084599-1 Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the vendors that received federal funds. Cause: Bothwell Regional Health Center did not have suspension and debarment controls in place prior to purchases with the vendors. Effect or Potential Effect: Federal funds could be paid to entities that are suspended or debarred. Questioned Costs: None noted. Context: Only one vendor was subject to the suspension and debarment requirement in 2024 and was selected for testing. The Health Center purchased $961,978 in goods/services from this vendor in 2024. During our testing, we noted the vendor utilized by the Health Center was not evaluated for suspension and debarment. Upon subsequent check, the vendor was not suspended or debarred. Identification of Prior Year Finding: N/A Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include vendors, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: Management agrees with the finding and management will implement a control process to ensure that suspension and debarment checks are performed on vendors/contracts funded with grants in 2025.

U.S. Department of Health and Human Services Direct Program: COVID-19 Provider Relief Fund - 93.498 Criteria or Specific Requirement - Reporting (Pub L. No 116-136, 134 Stat. 563 and Pub L. No. 116-139, 134 Stat. 622 and 623). The Provider Relief Fund (PRF) was established in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act, P.L. 116-136) to reimburse, through grants or other mechanisms, eligible health care providers for increased expenses or lost revenue attributable to Coronavirus Disease (COVID-19). Entities that received more than $10,000 (either one time or in the aggregate) are required to report the uses of their funds, including the lost revenue reimbursement and documentation of how the lost revenue was calculated. Condition - The Health Center did not properly report revenues by quarter in the period 4 HHS Provider Relief Fund (PRF) portal. Questioned Costs - None Context - Upon testing the period 4 report, six out of the eight quarters of actual revenues within 2021 and 2022 included in the portal did not tie to the Health Center's internal financial statements. Effect - The Health Center submitted revenues that were incorrect for the last two quarters of 2021 and all four quarters for 2022. This error in reporting did not lead to a change in the amount of lost revenues available to be used by the Health Center (all quarters reported zero lost revenues). Cause - The guidance provided by HHS to providers across the country as to how to report their COVID-19-related expenses and lost revenues is, at times, difficult to comprehend and apply. The Health Center's review processes over the portal submission failed to detect the errors. Identification as a Report Finding - Not applicable. Recommendation - The Health Center should continue to refine its understanding of the guidance related to this type of reporting and work with their external advisors to identify areas for improvement prior to submission to the Provider Relief Fund reporting portal. View of Responsible Official and Planned Corrective Actions - The Health Center agrees with this finding, however, does note that this did not in any way impact the amount of lost revenues available to be used under Provider Relief Fund program guidance. See separate auditee document for planned corrective action.