Baptist HealthNon-Profit

U.S. Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.007 Federal Supplemental Educational Opportunity Grants; Assistance Listing No. 84.063 Federal Pell Grant Program; Assistance Listing No. 84.268 Federal Direct Student Loans Program Year 2023 Criteria: Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition: The College's processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned Costs: None. Context: Out of the population of 336 students with student attendance changes, a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The College did not report the address change within 60 days for one student, and the College did not ensure submission of enrollment status changes within 60 days for two students. Effect: The College reported incorrect data for students' status changes and did not report the status changes timely. Cause: The College’s processes did not ensure status changes were reported timely and accurately. Identification as a Repeat Finding, if Applicable: N/A Recommendation: The College should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of Responsible Officials and Planned Corrective Actions: Administration concurs with the finding. Financial Aid Director will begin receiving email correspondence regarding enrollment report submission due dates from the National Student Clearinghouse. They will then confirm with the Registrar that the report was submitted by the due date each month. This will implement controls to ensure timely submission of address changes and enrollment reporting in the less than the 60-day requirement.

U.S. Department of Education Student Financial Assistance Cluster Assistance Listing No. 84.007 Federal Supplemental Educational Opportunity Grants; Assistance Listing No. 84.063 Federal Pell Grant Program; Assistance Listing No. 84.268 Federal Direct Student Loans Program Year 2023 Criteria: Special Tests and Provisions – Using a Servicer or Financial Institution to Deliver Title IV Cred Balances to a Card or Other Access Device (34 CFR 668.164(e) and (f). Condition: The College did not comply with certain requirements of Using a Servicer or Financial Institution to Deliver Title IV Cred Balances to a Card or Other Access Device. Questioned Costs: None. Context: The College entered into a contract with a servicer to deliver Title IV credit balances in 2018 but did not provide the contract URL to the Department of Education or include the contract on the College's website. The contract does not include a stated provision that the contract may be terminated based on student complaints nor does it discuss surcharge-free ATMs. The College did not perform a formal due diligence review of the contract fees, as required, every two years. The College did not post fee information within 60 days of the award year to its website and did not send cost information to the Department of Education. Effect: The College was not in compliance with the requirements noted above. Cause: The College’s internal controls did not ensure compliance with Department of Education requirements related to using a servicer to deliver Title IV credit balances to students. Identification as a Repeat Finding, if Applicable: N/A Recommendation: The College should update its controls to ensure compliance with Department of Education requirements for using a servicer to deliver Title IV funds. Views of Responsible Officials and Planned Corrective Actions: The College has reviewed the requirement in 34 CFR 668.164(e) and (f) and the required information will be corrected and the information will be submitted to the Department of Education and uploaded to the College's website by October 31, 2024.

Department of Health and Human Services HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Assistance Listing 93.461 Program Year 2022 Criteria: Eligibility ? Per 2 CFR Part 200, services must be for individuals, who at the time the services were provided, were uninsured as described in the terms and conditions. Condition: The Corporation received program funds for a patient who had insurance coverage. Questioned Costs: Projected questioned costs are estimated to be $703.74. Context: Two patients were initially considered uninsured, and the claims were billed to the federal program. It was later determined that the patients had insurance coverage through Arkansas Blue Cross; however, the refund process for the program funds was not initiated until this error was noted during the audit. We tested a random sample of 40 claims billed to the federal program during 2022, from a total population of 3,432 claims billed to the federal program. This error was noted for two claims out of the 40 sampled. The sample was not intended to be, and was not, a statistically valid sample. Effect or Potential Effect: Program funds were drawn to cover a claim for a patient who had insurance. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program?s eligibility requirements. Identification as a Repeat Finding: Yes, 2021-002 Recommendation: We recommend implementing controls to ensure review of patient insurance coverage and that the refund process is completed timely. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation and will implement controls to ensure all patient insurance coverage is reviewed and that the refund process is completed timely.

Criteria: Reporting ? Per 2 CFR Part 200, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution?s count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. A quarterly report for institutional portion expenditures was not submitted timely. Questioned Costs: None Context: Students eligible to receive an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. For the Spring 2021 semester, the Corporation reported 391 students were eligible to receive emergency funding instead of the actual number, 390, a difference of 1 student. Additionally, the second quarter institutional fund report was submitted 17 days after the July 10, 2021 deadline. We tested 100% of reports submitted and disclosures posted during 2021; therefore, no sampling methodology was used. Effect: The disclosures on the website are not accurate. Quarterly reports are not submitted timely. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program's reporting requirements. Identification as a Repeat Finding: 2020-001 Recommendation: We recommend implementing controls to ensure review of disclosures on the website and timely submission of quarterly reports. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation and will implement controls to ensure all disclosures are reviewed and all reports are submitted timely.

Criteria: Eligibility ? Per 2 CFR Part 200, services must be for individuals, who at the time the services were provided, were uninsured as described in the terms and conditions. Condition: The Corporation received program funds for a patient who had insurance coverage. Questioned Costs: Projected questioned costs are estimated to be $49,818. Context: A patient was initially considered uninsured, and the claim was billed to the federal program. It was later determined that the patient had insurance coverage through Arkansas Medicaid; however, the refund process for the program funds was not initiated until this error was noted during the audit. We tested a random sample of 40 claims billed to the federal program during 2021, from a total population of 9,293 claims billed to the federal program. This error was noted for 1 claim out of the 40 sampled. The sample was not intended to be, and was not, a statistically valid sample. Effect: Program funds were drawn to cover a claim for a patient who had insurance. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program's eligibility requirements. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend implementing controls to ensure review of patient insurance coverage and that the refund process is completed timely. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation and will implement controls to ensure all patient insurance coverage is reviewed and that the refund process is completed timely.

Criteria: Reporting - Per 2 CFR Part 200, institutions must publicly display on their website the total number of students who have received an Emergency Financial Aid Grant. Institutions are required to submit quarterly budget and expenditure reports detailing institutional expenditures of HEERF funds. Condition: The institution's count of number of students who have received an Emergency Financial Aid Grant disclosed on the website is not accurate. The quarterly reports for institutional portion expenditures were not submitted timely. Questioned Costs: None Context: Students receiving an Emergency Financial Aid Grant were reported incorrectly. We received the listing of students used for the reporting disclosures and performed recounts. As of June 30, 2020, the Corporation reported 679 students had received grants instead of the actual number, 352, a difference of 327 students. As of September 30, 2020, 528 students were incorrectly reported as receiving grants instead of the actual number, 295, a difference of 233 students. Additionally, the third quarter institutional fund report was submitted 14 days after the October 30, 2020, reporting deadline, and the fourth quarter institutional fund report was submitted two days after the January 10, 2021, reporting deadline. We tested 100% of reports submitted and disclosures posted during 2020; therefore, no sampling methodology was used. Effect: The disclosures on the website are not accurate. Quarterly reports are not submitted timely. Cause: Internal controls were not adequately designed and implemented to ensure compliance with the program's reporting requirements. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend implementing controls to ensure review of disclosures on the website and timely submission of quarterly reports. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation and will implement controls to ensure all disclosures are reviewed and all reports are submitted timely.