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ALABAMA NURSING HOME ASSOCIATION EDUCATION FOUNDATIONNon-Profit

EIN: 631074164

UEI: WEGVDAKJSM91

Audited by: CARR, RIGGS & INGRAM, LLC

Cognizant agency: 21 [Department of the Treasury]

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Data as of September 2, 2026

ALABAMA NURSING HOME ASSOCIATION EDUCATION FOUNDATION3 audit years5 findings1 repeat
3
Audit Years
5
Total Findings
1
Repeat Findings
$79.9M
Federal Awards Expended (FY 2022)

FY 2022-12-31

LOW-RISK AUDITEE$79,939,580 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 28, 2023. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 28, 2024 (890 days ago).

What is a management decision? →
2022-001
Activities Allowed or Unallowed / Cost Allowability / Period of Performance
SIGNIFICANT DEFICIENCY

2022-001 ? SIGNIFICANT DEFICIENCY ? Internal Controls Over Allowable Activities/Costs and Period of Performance U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID 19 Coronavirus State and Local Fiscal Recovery Fund ? ALN #21.027 ? Program Year 2022 Criteria ? Per 2 CFR Subpart D - 200.203(b)(3), non-federal entities are required to maintain records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. In addition, per CFR 200.303(a), non-federal entities are required to establish and maintain effective internal controls over federal awards. Condition ? For all 60 disbursements sampled, the Foundation relied solely on certifications received (with or without supporting documentation submitted) in order to disburse funds under the federal award program. Cause ? Based on guidance received from the grantor, the Foundation relied solely on certifications received (with or without supporting documentation submitted) in order to disburse funds under the federal award program. Effect ? Potential disbursements of federal awards for un-allowed costs/activities or in an improper period of availability. Questioned costs ? Unknown Auditors? recommendation ? Policies and procedures should be designed, implemented, and monitored to ensure that detailed supporting documentation is obtained and reviewed for all disbursements in accordance with federal award requirements. Management response and current status ? See management corrective action plan

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Full finding narrative

2022-001 ? SIGNIFICANT DEFICIENCY ? Internal Controls Over Allowable Activities/Costs and Period of Performance U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID 19 Coronavirus State and Local Fiscal Recovery Fund ? ALN #21.027 ? Program Year 2022 Criteria ? Per 2 CFR Subpart D - 200.203(b)(3), non-federal entities are required to maintain records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. In addition, per CFR 200.303(a), non-federal entities are required to establish and maintain effective internal controls over federal awards. Condition ? For all 60 disbursements sampled, the Foundation relied solely on certifications received (with or without supporting documentation submitted) in order to disburse funds under the federal award program. Cause ? Based on guidance received from the grantor, the Foundation relied solely on certifications received (with or without supporting documentation submitted) in order to disburse funds under the federal award program. Effect ? Potential disbursements of federal awards for un-allowed costs/activities or in an improper period of availability. Questioned costs ? Unknown Auditors? recommendation ? Policies and procedures should be designed, implemented, and monitored to ensure that detailed supporting documentation is obtained and reviewed for all disbursements in accordance with federal award requirements. Management response and current status ? See management corrective action plan

Corrective Action Plan

Finding 2022-001 ?Internal Control Over Allowable Activities/Costs and Period of Performance Status: Plan is being formulated. Planned Corrective Action: The Foundation followed the express instructions of the State of Alabama, Department of Finance (the ?Grantor?) to The Alabama Nursing Home Association Education Foundation (the ?Foundation?), which permitted the Foundation to rely upon the certifications of nursing home applicants that the applicant had or will have sufficient unmet needs related to qualifying purposes due to the COVID-19 pandemic to support the receipt of the various allocations of the herein described COVID-19 Funds. Under the terms of the certification, each applying nursing home further certified that for ten (10) years it would maintain auditable records supporting the unmet need and use of the COVID-19 Funds. This manner of requiring only a certification for the distribution to health care providers is consistent with the requirements the federal government used when distributing an array of emergency funding (e.g., provider relief funds, rural funds, and infection control funds) to health care providers to meet the unmet needs caused by the COVID-19 pandemic. The term ?COVID-19 Funds? means those funds the Foundation received from the Grantor with respect to (i) The CARES Act Corona Virus Relief Funds for the period from January 31, 2020 through December 31, 2021, and (ii) America Rescue Plan Act (ARPA) funds for unmet needs for qualifying purposes incurred or to be incurred during the period March 11, 2021 through December 31, 2024. To provide further assurance that the COVID-19 Funds were properly applied by the nursing home beneficiaries receiving COVID-19 Funds through the Foundation, the Foundation is working with its outside accountants and legal counsel to develop a look-back review plan. The framework of the look-back review plan will be for each nursing home beneficiary that received COVID-19 Funds to submit during the first month of the third quarter of the calendar year 2024, a worksheet similar to the period reporting worksheets that are required by the federal Health Resources & Services Administration (HRSA) to justify the COVID-19 provider relief funds, rural funds, and infection control funds received by health care providers. In addition to these HRSA type worksheets, a more in-depth examination of a sample of nursing homes will be made by randomly selecting 10 nursing homes from a pool of the 30 nursing homes that received the most COVID-19 Funds through the Foundation, plus another 15 nursing homes from the remainder of the pool of beneficiary nursing homes. These randomly selected nursing homes will be required to supply actual documentation supporting the COVID Funds received. This documentation will include invoices, payroll records, revenue journals, and cost reports. Among the provisions of the certifications submitted by each applying nursing home, is an acknowledgement that (i) the nursing home is subject to audit by the applicable State and federal agencies, and the Foundation, (ii) any COVID-19 Funds received through the Foundation and not properly applied must be refunded, and the nursing home will comply with the requirement that it must maintain for ten (10) years auditable records supporting its use of the COVID-19 Funds it received through the Foundation. In the event that it is determined that one or more nursing homes were unable to properly apply the COVID-19 Funds to an unmet need for a qualifying purpose, those COVID-19 Funds will be recouped and either redistributed to any nursing homes that are able show an unmet need continues to exist using a distribution formula consistent with past distributions of refunded COVID-19 Funds, or returned to the Grantor. This redistribution or return to the Grantor will occur no later than December 31, 2024. Person(s) Responsible: John Matson, Acting Executive Director Completion Date: Adoption of the Look-Back Audit Procedures December 31, 2023

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance →
2022-002
Reporting
SIGNIFICANT DEFICIENCY

2022-002 ? SIGNIFICANT DEFICIENCY ? Internal Controls over Reporting U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID 19 Coronavirus State and Local Fiscal Recovery Fund ? ALN #21.027 ? Program Year 2022 Criteria ? Per 2 CFR Subpart D - 200.329(a), non-federal entities are responsible for oversight of the operations of federal award supported activities and must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. In addition, per CFR 200.303(a), non-federal entities are required to establish and maintain effective internal controls over federal awards. Condition ? The Foundation did not maintain supporting documentation of the proper review and approval of the required final report for the federal award program. Cause ? Appropriate policies and procedures were not implemented by the Foundation to maintain documentation of the review and approval of the final report for the federal award program. Effect ? Lack of documentation of monitoring could lead to improper monitoring of federal award activity and possible misuse of funds. Questioned Costs ? None Auditors? Recommendation ? Policies and procedures should be designed, implemented, and monitored to ensure that documentation is maintained for the Foundation?s monitoring of its federal award program in accordance with federal award requirements. Management response and current status ? See management corrective action plan

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Full finding narrative

2022-002 ? SIGNIFICANT DEFICIENCY ? Internal Controls over Reporting U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID 19 Coronavirus State and Local Fiscal Recovery Fund ? ALN #21.027 ? Program Year 2022 Criteria ? Per 2 CFR Subpart D - 200.329(a), non-federal entities are responsible for oversight of the operations of federal award supported activities and must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. In addition, per CFR 200.303(a), non-federal entities are required to establish and maintain effective internal controls over federal awards. Condition ? The Foundation did not maintain supporting documentation of the proper review and approval of the required final report for the federal award program. Cause ? Appropriate policies and procedures were not implemented by the Foundation to maintain documentation of the review and approval of the final report for the federal award program. Effect ? Lack of documentation of monitoring could lead to improper monitoring of federal award activity and possible misuse of funds. Questioned Costs ? None Auditors? Recommendation ? Policies and procedures should be designed, implemented, and monitored to ensure that documentation is maintained for the Foundation?s monitoring of its federal award program in accordance with federal award requirements. Management response and current status ? See management corrective action plan

Corrective Action Plan

Finding 2022-002 ?Internal Control Over Reporting Status: Completed. Planned Corrective Action: Management will retain documentation of review of reports. Person(s) Responsible: John Matson, Acting Executive Director Completion Date: September 26, 2023

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2022-003
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

2022-003 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Based on Incorrect Calculations of Amounts to be Reimbursed (Continued) Condition ? For 3 of 60 disbursements sampled, reimbursed claims amounts included un-allowable costs due to the reimbursement calculations being performed incorrectly in the determination of the appropriate reimbursement amount. Cause ? As a result of the Foundation?s reliance solely on certifications received, amounts were not appropriately disbursed under the federal award program. Effect ? Claims payments included amounts that were not chargeable or assignable to the federal award in accordance with relative benefits received. Questioned Costs ? $148,871 known questioned costs (total amounts paid based on incorrect reimbursement calculations), $1,092,230 likely questioned costs ? amount extrapolated to entire population based on % of known questioned costs. Auditors? Recommendation ? Policies and procedures should be designed, implemented, and monitored which ensure that detailed supporting documentation is obtained and reviewed for all disbursements in accordance with federal award requirements. In addition, all calculations of amounts to be reimbursed should be appropriately recalculated to ensure the proper amount is included in the claims payments. Management response and current status ? See management corrective action plan

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Full finding narrative

2022-003 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Based on Incorrect Calculations of Amounts to be Reimbursed (Continued) Condition ? For 3 of 60 disbursements sampled, reimbursed claims amounts included un-allowable costs due to the reimbursement calculations being performed incorrectly in the determination of the appropriate reimbursement amount. Cause ? As a result of the Foundation?s reliance solely on certifications received, amounts were not appropriately disbursed under the federal award program. Effect ? Claims payments included amounts that were not chargeable or assignable to the federal award in accordance with relative benefits received. Questioned Costs ? $148,871 known questioned costs (total amounts paid based on incorrect reimbursement calculations), $1,092,230 likely questioned costs ? amount extrapolated to entire population based on % of known questioned costs. Auditors? Recommendation ? Policies and procedures should be designed, implemented, and monitored which ensure that detailed supporting documentation is obtained and reviewed for all disbursements in accordance with federal award requirements. In addition, all calculations of amounts to be reimbursed should be appropriately recalculated to ensure the proper amount is included in the claims payments. Management response and current status ? See management corrective action plan

Corrective Action Plan

Finding 2022-003 ?Claims Payments Made Based on Incorrect Calculations of Amounts Reimbursed Status: Under completion. Planned Corrective Action: A review was made by the Foundation?s outside accounting firm engaged to process claims and the errors cited in Finding 2022-003 resulted in only one overpayment to a nursing home. This was confined to a single nursing home that received more than that nursing home would have been entitled to receive under the adopted allocation regime. That nursing home was contacted and has promptly refunded the overage. The Foundation plans to redistribute this amount to other nursing facilities with unmet needs on a ratio and proportion basis. Person(s) Responsible: John Matson, Acting Executive Director Completion Date: October 31, 2023

About Allowable Costs / Cost Principles →

FY 2021-12-31

$12,160,835 federal awards expended

FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.

2021-001
Activities Allowed or Unallowed / Cost Allowability / Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2020-002QUESTIONED COSTSOTHER MATTERS

2021-001 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Without Appropriate Supporting Documentation U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID-19 Coronavirus Relief Fund ? ALN #21.019 Criteria ? Per 2 CFR 200.303, non-federal entities are required to establish and maintain effective internal controls related to federal awards and per 2 CFR 200.403(g), non-federal entities are required to ensure that costs are adequately documented in order to be allowable under federal awards. In addition, the grant award document for the Foundation?s federal awards requires that the claim submittals from nursing homes seeking Coronavirus Relief Funds must contain ?Documentation supporting the request (such as copies of invoices, purchase orders, summary payroll records, and/or evidence of insufficient revenue for the nursing home to be able to meet the COVID-19 Public Health Emergency)?. Condition ? 5 of 51 disbursement samples (claims paid) did not maintain documentation of the internal control over compliance related to allowable activities, allowable costs, and period of performance. 3 of 51 disbursements samples (claims paid) were paid without obtaining proper supporting documentation for amounts claimed. Effect ? Amounts paid could be for un-allowed costs/activities or in an improper period of availability. Cause ? Due to the unusual circumstances related to the COVID pandemic and the State of Alabama?s request for a quick distribution of funds related to the program, in some cases (and in reliance on sworn attestations), internal control over compliance was not monitored and supporting documentation was not maintained for all claims payments. Questioned costs - $112,130 known questioned costs (total of amounts paid without supporting documentation), $211,980 likely questioned costs ? amount extrapolated to entire population based on % of known questioned costs. Auditors? recommendation ? Proper control procedures should be put in place to ensure supporting documentation is obtained for all claims amounts prior to payment. Management response and current status ? See management corrective action plan

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Full finding narrative

2021-001 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Without Appropriate Supporting Documentation U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID-19 Coronavirus Relief Fund ? ALN #21.019 Criteria ? Per 2 CFR 200.303, non-federal entities are required to establish and maintain effective internal controls related to federal awards and per 2 CFR 200.403(g), non-federal entities are required to ensure that costs are adequately documented in order to be allowable under federal awards. In addition, the grant award document for the Foundation?s federal awards requires that the claim submittals from nursing homes seeking Coronavirus Relief Funds must contain ?Documentation supporting the request (such as copies of invoices, purchase orders, summary payroll records, and/or evidence of insufficient revenue for the nursing home to be able to meet the COVID-19 Public Health Emergency)?. Condition ? 5 of 51 disbursement samples (claims paid) did not maintain documentation of the internal control over compliance related to allowable activities, allowable costs, and period of performance. 3 of 51 disbursements samples (claims paid) were paid without obtaining proper supporting documentation for amounts claimed. Effect ? Amounts paid could be for un-allowed costs/activities or in an improper period of availability. Cause ? Due to the unusual circumstances related to the COVID pandemic and the State of Alabama?s request for a quick distribution of funds related to the program, in some cases (and in reliance on sworn attestations), internal control over compliance was not monitored and supporting documentation was not maintained for all claims payments. Questioned costs - $112,130 known questioned costs (total of amounts paid without supporting documentation), $211,980 likely questioned costs ? amount extrapolated to entire population based on % of known questioned costs. Auditors? recommendation ? Proper control procedures should be put in place to ensure supporting documentation is obtained for all claims amounts prior to payment. Management response and current status ? See management corrective action plan

Corrective Action Plan

MANAGEMENT?S CORRECTIVE ACTION PLAN Finding 2021-001 ?Claims Payments Made Without Appropriate Supporting Documentation Status: Completed. Planned Corrective Action: After a prompt internal review by management and the Chair of the Board of Trustees, the matter was brought to the attention of the Foundation?s outside CPA firm engaged to process claims. The CPA firm was able to locate or obtain documentation for all of the cited instances, except the instance caused by a worksheet glitch. The worksheet was created to subtract from the amount claimed certain Medicaid payments received for COVID purposes. In a single case, the Medicaid COVID add-on was entered into a worksheet cell as a negative number which due to the programing caused it to be added to the amount claimed as opposed to subtracted from the amount claimed. The affected facility has agreed to refund the amount in question and those sums will be allocated to other permitted uses or returned to grantor. Management reviewed all other worksheets and determined that no other worksheet was completed in a like manner. Management and the CPA firm have discussed approaches to ensure that the proper control procedures in place will be followed to ensure adequate supporting documentation is obtained for all claims amounts prior to payment. The creator of the worksheet in question is taking steps to correct the glitch so an amount entered into that particular cell, whether as a negative or positive number, will always be deducted from the amount claimed. Person(s) Responsible: John Matson, Acting Executive Director Completion Date: September 30, 2022

Prior Finding References

2020-002

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance →

FY 2020-12-31

$68,703,100 federal awards expended

FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.

2020-002
Activities Allowed or Unallowed / Cost Allowability / Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

2020-002 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Without Appropriate Supporting Documentation U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID-19 Coronavirus Relief Fund ? CFDA #21.019 Criteria ? Per 2 CFR 200.303, non-federal entities are required to establish and maintain effective internal controls related to federal awards and per 2 CFR 200.403(g), non-federal entities are required to ensure that costs are adequately documented in order to be allowable under federal awards. In addition, the grant award document for the Foundation?s federal awards requires that the claim submittals from nursing homes seeking Coronavirus Relief Funds must contain ?Documentation supporting the request (such as copies of invoices, purchase orders, summary payroll records, and/or evidence of insufficient revenue for the nursing home to be able to meet the COVID-19 Public Health Emergency)?. Condition ? 6 of 60 sampled claims payments were paid without obtaining proper supporting documentation for amounts claimed. Effect ? Amounts paid could be for un-allowed costs/activities or in an improper period of availability. Cause ? The Foundation failed to obtain proper supporting documentation prior to claims payment. Questioned costs - $170,949 known questioned costs (total of amounts paid without supporting documentation), $1,827,248 likely questioned costs ? amount extrapolated to entire population based on % of known questioned costs. Auditors? recommendation ? Proper control procedures should be put in place to ensure supporting documentation is obtained for all claims amounts prior to payment. Management response and current status ? See management corrective action plan

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Full finding narrative

2020-002 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Without Appropriate Supporting Documentation U.S. Department of Treasury ? Passed through the State of Alabama Department of Treasury ? COVID-19 Coronavirus Relief Fund ? CFDA #21.019 Criteria ? Per 2 CFR 200.303, non-federal entities are required to establish and maintain effective internal controls related to federal awards and per 2 CFR 200.403(g), non-federal entities are required to ensure that costs are adequately documented in order to be allowable under federal awards. In addition, the grant award document for the Foundation?s federal awards requires that the claim submittals from nursing homes seeking Coronavirus Relief Funds must contain ?Documentation supporting the request (such as copies of invoices, purchase orders, summary payroll records, and/or evidence of insufficient revenue for the nursing home to be able to meet the COVID-19 Public Health Emergency)?. Condition ? 6 of 60 sampled claims payments were paid without obtaining proper supporting documentation for amounts claimed. Effect ? Amounts paid could be for un-allowed costs/activities or in an improper period of availability. Cause ? The Foundation failed to obtain proper supporting documentation prior to claims payment. Questioned costs - $170,949 known questioned costs (total of amounts paid without supporting documentation), $1,827,248 likely questioned costs ? amount extrapolated to entire population based on % of known questioned costs. Auditors? recommendation ? Proper control procedures should be put in place to ensure supporting documentation is obtained for all claims amounts prior to payment. Management response and current status ? See management corrective action plan

Corrective Action Plan

Finding 2020-002 ? SIGNIFICANT DEFICIENCY ? Claims Payments Made Without Appropriate Supporting Documentation Status: In progress. Planned Corrective Action: After a prompt internal review by management and the Chair of the Board of Trustees, the matter was brought to the attention of the Foundation?s outside CPA firm engaged to process claims. The CPA firm was able to obtain documentation for all but a small amount of the cited $170,949 in claims. Each affected facility was prompt in responding to the request. Management and the CPA firm have discussed approaches to ensure that the proper control procedures in place will be followed to ensure adequate supporting documentation is obtained for all claims amounts prior to payment. Person(s) Responsible: John Matson, Acting Executive Director Estimated Completion Date: April 30, 2022

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