Texas Health Huguley, Inc.

Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services (HHS) Health Resources and Services Administration (HRSA) Assistance Listing: 93.461 ? COVID-19 HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Award Year: 2021 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management, in certain instances, did not retain documentary evidence that it performed procedures to verify patients? self-insurance status to ensure that the patients did not have any health care coverage at the time the services were rendered. Management represented that it inquired of the patients for insurance coverage, if any, prior to providing the services. However, no documentation was retained to support these inquiries. In addition, there was no documentary evidence of other procedures performed to support that a reasonable effort beyond inquiry was performed by management to verify the uninsured status of the patients. We also noted that the Company did not maintain sufficient documentation to support the effectiveness of internal controls in place to ensure balance billing was not performed. Cause: Management does not have sufficient internal controls in place to retain documentation of inquiries and other procedures performed to verify that patients were uninsured at the time services were provided. Internal controls over balance billing were not suitably designed to maintain supporting documentation to test the operating effectiveness of the internal controls. Effect or potential effect: Lack of adequate internal controls could result in claims for ineligible patients being submitted to HRSA. Questioned costs: $0 Context: We tested 40 patient claims that totaled $58,923 in HRSA reimbursement. For 8 of the 40 patient claims tested that totaled $193, there was no documentation supporting the procedures performed to ensure the uninsured status of the patient. The total HRSA payments on patient claims for FY 2021 was $4,320,997. Identification as a repeat finding, if applicable: Not applicable Recommendation: The Uninsured Program ended in the 2nd quarter of 2022. If the program were to continue, management should address the following recommendations. Management should enhance its internal controls to ensure that it documents the inquiries and retain support for other procedures performed to verify the uninsured status of the patients. Management should also ensure supporting documentation be retained to support the operating effectiveness of internal controls over balance billing. Views of responsible officials: Management agrees with the finding. Our standard procedure is to verify insurance coverage for all patients. For the samples noted in the finding, documentation was not maintained to evidence that additional insurance verification procedures were performed in addition to the standard patient inquiry. We believe this was a documentation error and not a process issue. Since the federal program has ended, no further action will be taken.

Information on the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Pass-Through Award Numbers: Not applicable Pass-Through Award Period of Performance: 01/01/2021?12/31/2021 Views of responsible officials and planned corrective actions: Management agrees with the finding. Our standard procedure is to verify insurance coverage for all patients. For the samples noted in the finding, documentation was not maintained to evidence that additional insurance verification procedures were performed in addition to the standard patient inquiry. We believe this was a documentation error and not a process issue. Since the federal program has ended, no further action will be taken. Management believes that appropriate balance billing controls are in place, however, documentation to evidence the design of the control was not maintained, which did not allow for testing of the effectiveness of the control. A component of the control environment for balance billing is an active workqueue within the billing system and documentation was not retained to evidence that the workqueue was designed effectively. The workqueue has been in place throughout the entirety of the COVID-19 pandemic and associated public health emergency and per internal review has been effective in identifying the proper patient accounts. Documentation has been established and will be retained effective September 30, 2022. Responsible official: James Mazzulla, Grants Manager Anticipated completion date: September 30, 2022

Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Pass-Through Award Numbers: Not applicable Pass-Through Award Period of Performance: 02/04/2020?12/31/2020 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Section 200.502 of the Uniform Guidance states the following regarding the financial statements: ?(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with 200.502.? Condition: Texas Health Huguley, Inc. was unable to determine the complete program expenditures to include on the schedule of expenditures of Federal awards. Cause: The Texas Health Huguley, Inc. billing department did not consistently code the payments related to the program to the appropriate payor class. Effect or potential effect: Texas Health Huguley, Inc. was unable to determine the the complete program expenditures to include on the schedule of expenditures of Federal awards. Questioned costs: The potential questioned costs are the difference between the amounts reported on the schedule of Federal awards of $2,093,638 up to the total of payments provided by Texas Health Huguley, Inc. of $2,139,703. Context: We selected 40 expenditures ($5,315) from 5774 total expenditures. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Texas Health Huguley, Inc. should ensure billing department personnel are appropriately coding the payments related to the program to the proper payor class, including sufficient review. Views of responsible officials: Texas Health Huguley, Inc. agrees with the finding and has developed a plan to correct the finding.

Information on the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Pass-Through Award Numbers: Not applicable Pass-Through Award Period of Performance: 02/04/2020?12/31/2020 Views of responsible officials and planned corrective actions: At the onset of the pandemic, logic was established to allow for quantification of federal funding received from the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured program. Due to the evolving nature of the pandemic, there were instances where the logic was not applied to all eligible patient accounts. Although this did not impact the proper submission of claims, it created limitations in reporting the full and complete population of federal funding received from the program. AdventHealth will implement internal controls to facilitate the consistent usage of the established logic. Responsible official: Grants Manager Anticipated completion date: December 31, 2022