GOTHENBURG MEMORAL HOSPITAL DISTRICTLocal Government

FINDING 2021-004 Program CFDA Number 93.498 U.S. Department of Health and Human Services COVID-19 Provider Relief Fund Criteria The terms and conditions of the CARES Act Provider Relief Fund (PRF) state costs associated with construction projects cannot be reimbursed using PRF payments unless the project was fully completed by the end of the Period of Availability associated with the payment received period. Condition During the process of identifying costs to include for PRF reporting, management reported costs associated with a building project that was not complete as of June 30, 2021. Cause Due to guidance regarding eligibility of building project costs being issued after the applicable Period of Availability, management inadvertently reported costs associated with a building project that was not fully completed as of June 30, 2021. Effect Management included amounts in the PRF reporting portal which were not eligible based on final guidance provided in the CARES Act PRF Frequently Asked Questions. (Continued) Questioned costs Total questioned costs amounted to $1,039,321. Perspective/Context Management was unaware PRF reporting guidance issued after June 30, 2021 stated costs associated with building projects not fully completed as of the Period of Availability were ineligible for PRF reporting purposes. This resulted in management inadvertently including costs of $1,039,321 in the PRF reporting form. Management reported approximately $1,338,000 of unreimbursed expenses attributable to Coronavirus that were not associated with the building project. Additionally management reported mortgage payments as an allowable expense but only included the principal portion of the payments and excluded the interest portion associated with these payments. Overall management appears to have potentially underreported total costs in this category by approximately $736,000. Recommendation Management should consider contacting HRSA and having them reopen the reporting portal for June 30, 2021 to correct the original filing for the above noted items. Additionally, we suggest reviewing the specific reporting guidance to assure any refiling and any future filings are done correctly. Views of responsible officials and planned corrective actions As noted above, our understanding of PRF reporting guidance after June 30, 2021 was inaccurate regarding building projects. We plan to contact HRSA and petition to reopen the portal to rectify our reporting errors. We now have a much clearer understanding of PRF reporting guidance and will use this knowledge in our refiling and any future filing.

FINDING 2021-005 INTERNAL CONTROLS OVER COMPLETION OF PROVIDER RELIEF FUND REPORTING - MATERIAL WEAKNESS Criteria Management should have a process in place to assure the most current and relevant Provider Relief Fund program (FAL 93.498) reporting guidelines are timely reviewed to assure all reporting requirements are met. Conditions Potential errors were noted in the reporting of certain costs for the reporting period ended June 30, 2021. Cause Guidance issued by the respective federal oversight agencies was changed numerous times during the expenditures reporting period resulting in management misinterpreting some of the final guidance as far as what costs could be included during the applicable reporting period. Additionally, the Hospital had limited available personnel to dedicate to this process resulting in a limited amount of time being available to review the applicable guidance. Effect and recommendation We suggest the Hospital continue to monitor and review the applicable guidance associated with this program to assure all required future reporting requirements are completed correctly. Views of responsible officials and planned corrective actions As noted above, guidance changed multiple times which presented challenges in maintaining current knowledge. A copy of FAL 93.498 has been obtained and we will continue to monitor and review any subsequent updates to the guidance.