West Park Hospital Distrcit dba: Cody Regional Health

Criteria Costs claimed against the Provider Relief Fund should be costs incurred related to preparing, responding, or preventing COVID-19. Condition Found and Context During our testing we noted costs claimed against the Provider Relief Fund from January and February 2020. These costs claimed had been reduced by a 33% estimated reimbursement from Medicare. While this is allowed under the guidelines the costs do need to be related to preparing, responding, or preventing COVID-19. As COVID-19 was not yet identified in Cody, Wyoming at that time it is unlikely these costs were related to COVID-19. Effect Potential over payment of costs related to COVID-19. Updated Questioned Costs $178,656 Cause Misinterpretation of Provider Relief Fund reporting guidelines. Recommendation We recommend the District review the Provider Relief Fund reporting guidelines to make sure the amounts claimed are in line with the guidelines. Views of Responsible Officials and Planned Corrective Actions As indicated the reporting of general and administrative (G&A) expenses for January and February 2020 resulted from the misinterpretation of Provider Relief Fund Reporting User Guide which instructed users to report expenses by calendar year quarter, and defined Quarter 1 2020 to be January 2020 through March 2020. In addition, the questioned costs noted above are based on reducing cost claimed by 33%. As noted in Finding 2021-007, the District also determined that COVID-related G&A expenses were actually underreported in Period 1 due to the fact that cost claimed should have only been reduced by 27.5%, rather than 33%. In total, after removing costs for January and February 2020 and correcting the cost reduction amount to 27.5%, total G&A expenses reported in Period 1 (Q1 2020 through Q2 2021) was understated by $279,332. The District plans to correct the reporting of G&A expenses based on these findings in its Period 3 reporting submission.

Criteria Lost revenues can be claimed against the Provider Relief Fund during the reporting period. Condition Found and Context During our testing we noted the Provider Relief Fund report was incorrectly completed and an additional $91,493 of lost revenues was reported. Effect Potential to overclaim lost revenue against the Provider Relief Fund. Questioned Costs None identified. Cause Clerical error in completion of the lost revenue reporting table in the Provider Relief Fund Period 1 report. Recommendation We recommend the District review the Provider Relief Fund reporting guidelines to make sure the amounts claimed are in line with the guidelines. We also recommend a review take place to make sure all amounts claimed are correctly calculated. Views of Responsible Officials and Planned Corrective Actions The District plans to correct the clerical error in the reporting of lost revenue of $91,493 in its Period reporting submission.

Criteria Coronavirus Relief Fund cannot be used to cover expenditures for which reimbursement is received from other sources. Condition Found and Context During our testing we noted the amounts reimbursed through the Coronavirus Relief Fund were not reduced by the cost-based portion reimbursed by Medicare through the Medicare cost report. Effect Potential to receive excess reimbursement from Coronavirus Relief Fund. Questioned Costs $384,240 Cause Management oversight in submitting costs for reimbursement that would be reimbursed through the Medicare cost report. Recommendation We recommend the District review the Coronavirus Relief Fund guidelines to make sure the amounts requested for reimbursement are in line with the guidelines. Views of Responsible Officials and Planned Corrective Actions Management acknowledges oversight of accounting for the 27.5% Medicare cost reimbursement reduction that should have been applied to the CRF funds. The District will review the latest Coronavirus Relief Fund guidelines prior to any future reporting to ensure that all necessary cost reductions are accounted for in the application of CRF funds.

Criteria Costs claimed against Provider Relief Fund should be reduced for amounts reimbursed from other sources. Condition Found and Context During our testing we noted the District reduced its costs claimed against the Provider Relief Fund by 33% based on an estimate. The actual costs reimbursed by Medicare through the Medicare cost report for 2020 and 2021 average to approximately 27.5%. As a result the District underreported the costs that could be claimed against the Provider Relief Fund. Effect Potential to underreport funds that can be claimed against the Provider Relief Fund. Questioned Costs None identified. Cause Clerical error in completion of the Provider Relief Fund Period 1 report. Recommendation We recommend the District review the Provider Relief Fund reporting guidelines to make sure the amounts claimed are in line with the guidelines. We also recommend a review take place to make sure all amounts claimed are correctly calculated. Views of Responsible Officials and Planned Corrective Actions As noted in 2021-004, total G&A expenses reported in Period 1 (Q1 2020 through Q2 2021) was understated by $279,332. The District plans to correct the reporting of G&A expenses based on these findings in its Period 3 reporting submission.