MONONGALIA HEALTH SYSTEM, INC. AND SUBSIDIARIES

Federal Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Award Number: N/A Award Year: 2021 Compliance Requirements: Reporting Questioned Costs: Not determinable Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Provider Relief Funds (PRF) payments must be used for allowable expenses and lost revenue described in the PRF terms and conditions and specified in guidance issued by the U.S. Department of Health and Human Services. Activities allowed have been defined as expense used to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Additionally, all recipients of PRF payments must comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition and context: Monongalia County General Hospital Company dba Mon Health Medical Center did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the facility had multiple errors in its underlying calculation of lost revenues which resulted in lost revenues being overstated $92,483. The entity reported total lost revenues of $66,955,875 on total PRF distributions that amounted to $21,763,852, as such, there were no questioned costs. Effect: The amounts reported to HRSA were not in accordance with established U.S. Department of Health and Human Services guidance. Cause: Monongalia Health System, Inc. and Subsidiaries had an insufficient control in place to identify and correct errors prior to reporting on the use of their Provider Relief Funds. Repeat Finding: 2021-005 Recommendation: We recommend that management review policies and procedures in place and update for most recent interpretation of the U.S. Department of Health and Human Services guidance. Procedures should be implemented and monitored. Unallowable cost recognized should be corrected in future reporting periods. Management's Response: Monongalia Health System, Inc. and Subsidiaries agrees with the finding.

2021-005: Material Weakness in Internal Control Over Compliance Federal Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing number: 93.498 Federal agency: U.S. Department of Health and Human Services Award Number: N/A Award Year: 2020 Compliance Requirements: Reporting Questioned Costs: $8,130 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Provider Relief Funds (PRF) payments must be used for allowable expenses and lost revenue described in the PRF terms and conditions and specified in guidance issued by the U.S. Department of Health and Human Services. Activities allowed have been defined as expense used to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Additionally, all recipients of PRF payments must comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition and Context: Stonewall Jackson Memorial Hospital and Stonewall Home Oxygen Therapy, Inc. (Hospital) did not complete it's combined PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the filing had multiple errors in its underlying calculation of lost revenues which resulted in lost revenues being overstated $8,130. The Hospital received distributions totaling $9,993,387 and reported total lost revenues of $6,980,009. Monongalia County General Hospital Company dba Mon Health Medical Center did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the facility had multiple errors in its underlying calculation of lost revenues which resulted in lost revenues being overstated $634,123. The entity reported total lost revenues of $56,834,741 on PRF distributions that amounted to $5,610,577, as such, there were no questioned costs. Preston Memorial Hospital Corporation did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the facility had multiple errors in its underlying calculation of lost revenues which resulted in lost revenues being overstated $159,573. The entity reported total lost revenues of $5,154,066 on PRF distributions that amounted to $4,834,739, as such, there were no questioned costs. Effect: The amounts reported to HRSA were not in accordance with established U.S. Department of Health and Human Services guidance. Cause: Monongalia Health System, Inc. and Subsidiaries had an insufficient control in place to identify and correct errors prior to reporting on the use of their Provider Relief Funds. Recommendation: We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood, and that information used in accumulating allowable lost revenues is reviewed, with errors addressed. Procedures should be performed on a monthly basis with previously recognized lost revenues being reviewed to ensure they qualify as allowable under the most recent guidance. Views of Responsible Officials: Monongalia Health System, Inc. and Subsidiaries agrees with the finding.

2021-006: Material Weakness in Internal Control Over Compliance, Material Noncompliance Federal Program: COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing number: 93.498 Federal agency: U.S. Department of Health and Human Services Award Number: N/A Award Year: 2020 Compliance Requirements: Activities Allowed or Unallowed Questioned Costs: $2,293,893 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Provider Relief Funds (PRF) payments must be used for allowable expenses and lost revenue described in the PRF terms and conditions and specified in guidance issued by the U.S. Department of Health and Human Services. Activities allowed have been defined as expense used to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse, through grants or other mechanisms, eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus. Additionally, all recipients of PRF payments must comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition and Context: Stonewall Jackson Memorial Hospital and Stonewall Home Oxygen Therapy, Inc. included expenses in its combined filing that did not meet criteria of an allowable expenses as defined by the U.S. Department of Health and Human Services guidance. The combined filing included various expenses associated with the facility that were not specifically used to prevent, prepare for, and respond to the coronavirus. During our testing we noted exceptions on 32 of 40 samples. Upon further analysis of the entire population, we noted that Stonewall Jackson Memorial Hospital and Stonewall Home Oxygen Therapy, Inc reported expenses associated with the facility that were not specifically used to prevent, prepare for, and respond to the coronavirus totaling $2,293,893. The Hospital received distributions totaling $9,993,387 and reported total expenses of $5,141,483. Our sample was not a statistically valid sample. Effect: The Health System claimed expenses that were not in accordance with established U.S. Department of Health and Human Services guidance and therefor deemed unallowable. Cause: Monongalia Health System, Inc. and Subsidiaries had an insufficient control in place to identify and correct errors prior to reporting on the use of their Provider Relief Funds. Recommendation: We recommend that management implement procedures to ensure that the most recent guidance is reviewed and understood, and that information used in accumulating allowable expenses and lost revenues is reviewed, with errors addressed. Procedures should be performed on a monthly basis with previously recognized expenses being reviewed to ensure they qualify as an allowable expense under the most recent guidance. Views of Responsible Officials: Monongalia Health System, Inc. and Subsidiaries agrees with the finding.