Advent Christian Village. Inc. and SubsidiariesNon-Profit

2021 ? 001-PRF Special Reporting Federal agency: U.S. Department of Health and Human Services Federal program title: Provider Relief Funds Assistance Listing Number: 93.498 Award Period: The reporting period 1-April 10, 2020, through June 30, 2020 Type of Finding: ? Material Weakness in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award. Under the terms and conditions of the award, Provider Relief Funds (PRF) is subject to 45 CFR section 75.302 (Financial management and standards for financial management systems). The PRF program requires special reporting through the Provider Relief Fund Reporting Portal that contains key line items containing critical information based on the period reported on. In accordance with the Coronavirus Response and Relief Supplemental Appropriations Act, a parent organization with direct ownership relationship with a subsidiary that received a Provider Relief Fund Targeted Distribution payment can control and allocate that distribution payment among other subsidiaries. Additionally, a parent organization with multiple billing TINS may attest to the Terms and Conditions and keep general payments as long as providers associated with the parent organization were providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Condition: The organization claimed lost revenues and expenses that were duplicated within the reporting portal for the multiple reporting EINS (TIN 651186341 and TIN 542118733). Questioned costs: None. Section III ? Findings and Questioned Costs ? Major Federal Programs(continued) 2021 ? 001-PRF Special Reporting (continued) Context: The reporting requirements were tested for the reporting entities ACV Health Services LLC and ACV Community Services LLC. The client did not create a parent TIN which reported on behalf of subsidiaries but rather created separate parent reporting entities and therefore there were two reports to test. In the testing of these reports, it was noted that each report mirrored the other, with exception of the actual targeted distribution receipts section of the report. All key line items were reported at the consolidated value rather than the value applicable to the reporting entity. Cause: The Organization received PRF funds under two of its EINs: ACV Health Services LLC (TIN 651186341) and ACV Community Services LLC (TIN 542118733). During the original reporting period, the client used ACV Health Services LLC as the parent entity but not all disbursements from HRSA were reflected in the portal to accept. As such, during a period when HRSA opened up the reporting period for correction, the client reported information under the EINS in order to capture all the PRF receipts. During the reporting requirement testing, auditors noted all key line items on both reports included the consolidated totals rather than the totals of the EIN reporting on the period, thereby duplicating all values. Effect: ACV reported lost revenues and expenses for the consolidated entity on both reporting portals due to the fact that the reporting portal for the subsidiary had PRF funds under the EIN of another subsidiary. This resulted in expenses and revenues being duplicated. Repeat Finding: No. Recommendation: Although management reached out to HRSA, they were unable to obtain a resolution as to how to report expenses and lost revenues in the reporting portal. We recommend that should this situation present itself in future years, the Organization obtain written guidance from HRSA on how to proceed with reporting expenses and revenues when HRSA included funds received by different subsidiaries. Views of responsible officials: Advent Christian Village, Inc. and Subsidiaries (ACV) believes that while the lost revenues and expenses were in fact duplicated, the decision to do so was made in good faith and appropriate based on the award amounts included on the HRSA portal. As described above the HRSA portal duplicated the awards for both ACV subsidiaries under two separate accounts. ACV recognized the errors and contacted HRSA support many times, over several weeks and spent numerous hours on the phone to get the issues resolved. While HRSA recognized their errors they were unable to correct them. The deadline for reporting arrived and ACV was forced to decide the most accurate way to report the results. Since HRSA duplicated the awards in two separate accounts, ACV had no alternative but to duplicate the lost revenues and expenses in both accounts. To report otherwise would have resulted in the forfeiture of award funds even though ACV?s lost revenues and expenses exceeded the amount of the awards. ACV has no control over HRSA?s portal and should not be penalized by their inability to provide accurate information.