EIN: 720502505
UEI: GBPMHQM2SRL3
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 27, 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 December 27, 2023 (974 days ago).
What is a management decision? →During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Show full finding ▾Hide full finding ▴Finding 2022-001: Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. Identification of the federal program: Assistance Listing Number 97.036: ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) ? U.S. Department of Homeland Security ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 ? Federal award year: o August 29, 2021 to October 10, 2021 o October 11, 2021 to April 17, 2022 ? Pass-through entity ? State of Louisiana Governor?s Office of Homeland Security and Emergency Preparedness Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR, Part 200, Section 200.84 ? Questioned costs states a questioned cost as either (a) which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for funds used to match Federal funds; (b) where the costs, at the time of the audit, are not supported by adequate documentation; or (c) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR, Part 200, Section 200.406 ? Applicable credits states (a) applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. The Office of Management and Budget Compliance Supplement states the Federal Emergency Management Agency (FEMA) evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. Costs must be: reduced by all applicable credits. Condition: During our testing over expenditures reimbursed by FEMA, we observed reported expenditures in the project worksheets were not reduced by all applicable credits resulting in an overstatement of the amount reimbursed by FEMA. Cause: Certain expenditures in the project worksheets submitted to FEMA for reimbursement were not reduced by all applicable credits. Effect or potential effect: Management was reimbursement by FEMA for expenditures that were not reduced by all applicable credits. Questioned costs: $99,285 ? Assistance Listing Number 97.036 ? Federal award identification number: o Application titles: ? 662759 ? Emergency Work Group #2 ? 662754 ? Emergency Work Group #2 o Application numbers: ? PA-06-LA-4611-PW-01437 ? PA-06-LA-4611-PW-01457 Questioned costs were computed by calculating the difference between the impacted expenditures submitted to FEMA in the amount of $923,105 and the expenditures value after reducing for all applicable credits in the amount of $823,820 resulting in $99,285. Context: During our testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, we obtained a listing of expenditures submitted for reimbursement to FEMA for the impacted project worksheets and observed 130 expenditures in the listing for a total value of $923,105 (total value factoring in the cost share was $888,900). We selected a sample of 21 for testing over activities allowed or unallowed and allowable costs/cost principals and a sample of 24 for testing over period of performance. There were certain expenditures identified in the sample selected that were not reduced for all applicable credits (i.e., the vendor provided a credit back to the entity for a previously paid invoice). Management evaluated the entire population of expenditures, and it was identified that $99,285 was the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable credits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management refund the questioned costs to FEMA and ensure future project worksheets are reduced for all applicable credits. Views of responsible officials: Ochsner will reach out to FEMA/GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA/GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout.
Finding 2022-001: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. During the course of the Ochsner Clinic Foundation Uniform Guidance (UG) Audit for the Year Ended December 31, 2022, EY identified the following finding, as reported in the Schedule of Findings and Questioned Costs: Finding 2022-001 - Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. This finding is associated with application numbers PA-06-LA-4611-PW-01437 and PA-06-LA-4611-PW-01457. Both of these Project Worksheets (PWs) are for external security services that Ochsner procured in the aftermath of Hurricane Ida. These PWs included a population of 130 expenditures (invoices) for a total value of $923,105 (total value factoring in the cost share was $888,900). FEMA obligated these PWs and payment was remitted to Ochsner (via GOHSEP) for the full cost share amount of $888,900. As part of their testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, EY selected a sample of 45 items from this population ? 21 for testing over activities allowed or unallowed and allowable costs/cost principals and 24 for testing over period of performance. Through their testing, EY identified certain expenditures in the sample that were not reduced for all applicable credits (i.e., the vendor provided a credit back to Ochsner for a previously paid invoice). As a result of these items identified in the sample, Management evaluated the entire population of expenditures, and identified $99,285 as the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable vendor credits. Ochsner did not identify these discrepancies when the PWs were filed with FEMA because the vendor invoices were used as the basis for the estimate of the claims, which is consistent with FEMA?s requirements. These vendor invoices reflected the full amounts billed by the vendor and did not reflect any credits that ultimately resulted in lesser amounts being remitted to the vendor at time of payment. The discrepancies that EY identified during the UG audit would have been identified, as is usually done, by either Ochsner or by FEMA / GOHSEP during the normal closeout process for these PWs, as discussed within the Public Assistance Program and Policy Guide (Version 4, Effective June 1, 2020) - Chapter 12: Final Reconciliation and Closeout. As part of this standard process, Ochsner will be required to provide proof of payment to FEMA / GOHSEP as part of the closeout process, at which time these discrepancies would have been identified. In order to cure this finding, Ochsner will reach out to FEMA / GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA / GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout. Responsible Official: Scott Whitfield, Ochsner Assistant Vice President - Treasury Anticipated Completion Date: December 31, 2023
FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.
Ochsner Clinic Foundation and Subsidiaries incorrectly reported lost revenues attributable to Coronavirus in the HRSA PRF Reporting Portal (the ?Portal?) due to errors made in the calculation of lost revenues by an overstatement of lost revenues of $6,927,991. Cause: Management did not have effective internal controls in place to ensure the reported lost revenues attributable to Coronavirus reported in the Portal were free from error. Effect or potential effect: The calculation of lost revenues attributable to Coronavirus was reported incorrectly in the Portal. Questioned costs: None. Context: During our testing over reporting, we obtained a listing of 14 PRF reports submitted to the Portal and selected a sample of 10. We observed the calculation of lost revenues attributable to Coronavirus included errors in 8 PRF reports which impacted the calculated lost revenue in the amount of $6,927,991. Total lost revenues submitted in the Portal were $281,349,325 for Period 1 and Period 2. Management?s control regarding the review of the PRF report and the supporting calculation did not identify these errors when submitting the Period 1 and Period 2 submissions into the Portal. The errors had no impact on meeting the requirements to retain the funding received. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management develop and implement effective internal controls to ensure accurate reporting in the Portal. This will ensure the calculation of lost revenues attributable to Coronavirus is reported correctly. Views of responsible officials: This administrative error overstated lost revenues and did not result in a refund of funds to HRSA. In future reporting periods, management will add an additional layer of review of detail calculations before submission through the portal. Management will correct the lost revenues attributable to Coronavirus in the next Portal submission.
Show full finding ▾Hide full finding ▴Finding 2021-001: Internal control deficiency and noncompliance over the calculation of lost revenues attributable to Coronavirus. Identification of the federal program: Assistance Listing Number 93.498: ? COVID-19 ? Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution ? U.S. Department of Health and Human Services ? Federal award identification number ? Not Applicable ? Federal award year: o Period 1 ? January 1, 2020 to June 30, 2021 o Period 2 ? January 1, 2020 to December 31, 2021 Criteria or specific requirement (including statutory, regulatory or other citation): Title 2, Subtitle A Chapter II Part 200 Subpart D 200.303 Internal controls. The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The terms and conditions of the award requires the recipient to submit reports as the secretary of HHS determines are needed to ensure compliance with conditions that are imposed on the payment, and such reports shall be in such form, with such content, as specified by the secretary of HHS in future program instructions directed to all recipients. Condition: Ochsner Clinic Foundation and Subsidiaries incorrectly reported lost revenues attributable to Coronavirus in the HRSA PRF Reporting Portal (the ?Portal?) due to errors made in the calculation of lost revenues by an overstatement of lost revenues of $6,927,991. Cause: Management did not have effective internal controls in place to ensure the reported lost revenues attributable to Coronavirus reported in the Portal were free from error. Effect or potential effect: The calculation of lost revenues attributable to Coronavirus was reported incorrectly in the Portal. Questioned costs: None. Context: During our testing over reporting, we obtained a listing of 14 PRF reports submitted to the Portal and selected a sample of 10. We observed the calculation of lost revenues attributable to Coronavirus included errors in 8 PRF reports which impacted the calculated lost revenue in the amount of $6,927,991. Total lost revenues submitted in the Portal were $281,349,325 for Period 1 and Period 2. Management?s control regarding the review of the PRF report and the supporting calculation did not identify these errors when submitting the Period 1 and Period 2 submissions into the Portal. The errors had no impact on meeting the requirements to retain the funding received. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that management develop and implement effective internal controls to ensure accurate reporting in the Portal. This will ensure the calculation of lost revenues attributable to Coronavirus is reported correctly. Views of responsible officials: This administrative error overstated lost revenues and did not result in a refund of funds to HRSA. In future reporting periods, management will add an additional layer of review of detail calculations before submission through the portal. Management will correct the lost revenues attributable to Coronavirus in the next Portal submission.
Finding 2021-001: Provider Relief Fund (Assistance Listing #93.498) Internal Control Deficiency and Non-Compliance over the Calculation of Lost Revenues attributable to Coronavirus. Since the start of the Covid-19 pandemic, Ochsner Clinic Foundation has coordinated efforts across multiple divisions throughout the organization to ensure compliance with the Provider Relief Fund that included leveraging publicly available information, outside consultants, and an internal review prior to management sign off. An additional quality control measure will be implemented whereby Ochsner?s Internal Audit Department will perform a detailed review of the calculation including tracing all formulas to ensure accuracy prior to management sign-off. In addition, Ochsner Clinic Foundation will work with HRSA to understand the most appropriate manner to correct this issue within the Provider Relief Fund Portal, along with any other actions needed for locations that do not have subsequent portal submissions. Responsible Official: Steven Stiles, Ochsner Vice President of Reimbursement Anticipated Completion Date: September 30, 2022
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