PIEDMONT HEALTHCARE, INC.Non-Profit

Finding No: 2022-001 Activities Allowed or Unallowed/Allowable Costs Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 Program: COVID -19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Year: January 1, 2020 through June 30, 2022 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity must 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. (b) Condition Found, Including Perspective During our test work, we selected a sample of 40 incentive bonus payments made during the fiscal year 2022 reporting period. We noted that PHC was unable to provide evidence of management review and approval for each of the incentive bonus payments sampled. These disbursements were made for allowable costs under the terms and conditions of the program. (c) Possible Cause PHC was unable to provide evidence of certain management reviews and approvals because the control was not designed to require the retention of documentation of management review at the transactional level. (d) Questioned Cost None. (e) Effect Evidence of the effective operation of management review controls was not maintained in accordance with Federal requirements. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year Repeat of prior year Finding No. 2021-001. (h) Recommendation We recommend that PHC strengthen controls over the management review process to enhance the retention of evidence of management review and approval. (i) View of Responsible Officials Management concurs with the finding. While we believe appropriate controls exist relating to the management review and approval of allowable costs at the transactional level, we concur that procedures relating to obtaining and maintaining documentation of such reviews need to be strengthened. Management will ensure communication of the finding to the reviewers and submitters of allowable costs and revise procedures to ensure documentation of reviews and approvals is obtained and maintained. Prior to submitting allowable costs to Health Resources and Services Administration (?HRSA?), we will obtain documentation of the approval of these costs and maintain this documentation in the same manner as the documentation of the submission of the costs to HRSA.

Finding No: 2021-001 Activities Allowed or Unallowed/Allowable Costs Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 Program: COVID -19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Year: January 1, 2020 through June 30, 2021 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity must 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. (b) Condition Found, Including Perspective During our test work, we selected a sample of 40 non-payroll disbursements and 40 incentive bonus payments made during the fiscal year 2021 reporting period. We noted that PHC was unable to provide evidence of management review and approval for each of the non-payroll disbursements and incentive bonus payments sampled. These disbursements were made for allowable costs under the terms and conditions of the program. (c) Possible Cause PHC was unable to provide evidence of certain management reviews and approvals because the control was not designed to require the retention of documentation of management review at the transactional level. (d) Questioned Cost None. (e) Effect Evidence of the effective operation of management review controls was not maintained in accordance with Federal requirements. (f) Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year Not a repeat finding. (h) Recommendation We recommend that PHC strengthen controls over the management review process to enhance the retention of evidence of management review and approval. (i) View of Responsible Officials Management concurs with the finding. While we believe appropriate controls exist relating to the management review and approval of allowable costs at the transactional level, we concur that procedures relating to obtaining and maintaining documentation of such reviews need to be strengthened. Management will ensure communication of the finding to the reviewers and submitters of allowable costs and revise procedures to ensure documentation of reviews and approvals is obtained and maintained. Prior to submitting allowable costs to Health Resources and Services Administration (?HRSA?), we will obtain documentation of the approval of these costs and maintain this documentation in the same manner as the documentation of the submission of the costs to HRSA.