CLARA BARTON HOSPITAL ASSOCIATION, INC.Non-Profit

Identification: 93.498 United States Department of Health and Human Services, COVID-19 Provider Relief Fund; Noncompliance Finding/Significant Deficiency; Reporting Compliance Requirement Criteria: The Provider Relief Fund (PRF) was established under the Coronavirus, Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and the Coronavirus Relief and Response Supplemental Appropriations Act (Pub. L. No. 116-260). Eligible healthcare providers received PRF appropriations for health-care related expenses or lost revenues attributable to coronavirus. Recipients who received one or more payments exceeding $10,000 are required to report in each applicable reporting period. Condition: The Hospital had one error in the Period 1 reporting submission. The Hospital incorrectly left out the 340(b) drug program revenue from the calculation of lost revenue. Cause: When the reporting guidance first came out the guidance indicated that the retail pharmacy revenue would not be included in the calculation of lost revenue. Updated guidance indicated that retail pharmacy would be included in the calculation of lost revenues. The Hospital's spreadsheet of lost revenue was not updated to include this change. Effect: The Hospital understated their lost revenue for the Period 1 reporting by $236,075. Questioned costs: None Perspective information: We tested the Period 1 report submitted during the reporting period to supporting documentation to determine if the report was completed accurately. Repeat Finding: N/A Recommendations: We recommend policies and procedures over federal grant reporting be strengthened to ensure required reports are completed accurately. Views of Responsible Officials: There were multiple changes regarding guidance on the proper reporting data. At the time, the Hospital set up their calculations for lost revenues, the guidance clarifying the inclusion of the 340(b) drug program revenue as part of the lost revenue calculation was not available, thus, the Hospital elected to not include. The Hospital will include the 340(b) drug program revenue in future calculations.

Identification: 93.498 United States Department of Health and Human Services, COVID-19 Provider Relief Fund; Noncompliance Finding/Significant Deficiency; Allowable Activities Compliance Requirement Criteria: The Provider Relief Fund (PRF) was established under the Coronavirus, Aid, Relief, and Economic Security Act (CARES Act) (Pub. L. No. 116-136, 134 Stat. 563) and the Coronavirus Relief and Response Supplemental Appropriations Act (Pub. L. No. 116-260). The PRFs are to be used to prevent, prepare for, and respond to coronavirus. The PRFs are to reimburse recipients only for health care related expenses or lost revenues that are attributable to coronavirus. PRF funds received during Period 1, April 10, 2020 through June 30, 2020, have a period of availability of January 1, 2020 through June 30, 2021. For purchases of tangible items made using PRF payments, the purchase does not need to be in the provider's possession (i.e., back ordered PPE, ambulance, etc.) to be considered an eligible expense but the costs must be incurred by the end of the period of availability. Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses. Condition: The Hospital did not meet the requirement that the PRF funds be used for expenditures within the period of availability. The Hospital included $214,986 in expenditures that were outside the period of availability. Cause: The Hospital included a capital project to improve air quality that had a down payment that was outside the period of availability. In addition, the Hospital included furniture that was ordered and paid for on June 22, 2021, but was not received until September 29, 2021, and not considered an expense under generally accepted accounting principles until it was received. The furniture was not on back order as of June 30, 2021. Effect: Overstatement of PRF expenditures reported on Period 1 submission. Questioned costs: Known $214,986. However, the Hospital understated lost revenues by $236,075, see finding 2021-002. After consideration of the understatement of lost revenues, the Hospital had an additional $21,089 in lost revenues unused. Perspective information: In the sample of 60 and 6 individually significant, there were seven instances noted from the sample and one from individually significant that were outside the period of availability. Extrapolation was not necessary, as we were able to identify all furniture purchases that were outside the period of availability based on review of expenditure listing and invoices. The sample was a statistically valid sample. Repeat finding: N/A Recommendations: We recommend policies and procedures over federal grant reporting be strengthened to ensure expenditures applied to the federal grants are within the period of availability. Views of Responsible Officials: The process of tracking control will be improved within the Hospital accounting department by listing the government funding eligibility timeframe on the spreadsheet that is used to list the eligible expenditures tied to that specific grant program.