The Queen's Health SystemsNon-Profit

Information on Federal Programs U.S. Department of Health and Human Services: CFDA No. 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund; Award Year: 2021 - 2022. Specific Requirements/Criteria The terms and conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program allows for reimbursement of payment for COVID-19 testing and testing related items, COVID-19 treatment or COVID-19 vaccine administration fees as determined by the program for individuals who do not have any health care coverage at the time the services were rendered. Funds provided will not be used to reimbursed expenses that have been reimbursed from other sources. Condition During our testing of the internal controls and compliance over the Activities Allowed and Unallowed process, we noted controls that were designed to ensure that HRSA claims reimbursements were submitted for eligible individuals for certain locations associated with a certain urgent care subsidiary were ineffective in certain circumstances. To test the compliance of this process, we tested a total of 45 HRSA claim reimbursement transactions to ensure individuals were uninsured at the time of the service and received an allowable COVID-19 service as per the terms and conditions. We noted for a certain urgent care subsidiary, that 7 of the 8 tested claims were not eligible for reimbursement as the individual either did have insurance at the time of service or the claim was already reimbursed from other sources. The HRSA claims reimbursements associated with this certain urgent care subsidiary was $40,150 for the year ending June 30, 2022. The 7 tested claims that were not eligible for reimbursement were $100 each, which total to the $700 questioned costs. The sample was not intended to be, and was not, a statistically valid sample. This audit finding is reported as the likely questioned costs could possibly exceed the reporting threshold of $25,000. Management is evaluating the total amount to be remitted back to HRSA. Cause The above finding was caused by a lack of adequate training and monitoring at this certain urgent care subsidiary of the personnel tasked with submitting lab requisitions for COVID-19 tests performed. Effect The schedule of expenditures of federal awards is inappropriately stated as of June 30, 2022 because ineligible costs were charged to the program. Questioned Costs $700 Recommendation We recommend that QHS implement procedures and policies to ensure that the individuals included in HRSA claim reimbursements are uninsured at time of service and that the claim has not been reimbursed from other sources.

Program: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Agency Name: U.S. Department of Health and Human Services Federal Award Number: N/A Federal Award Year: 2021 – 2022 Federal Assistance Listing Number: 93.461 Compliance Requirement: Activities Allowed or Unallowed Criteria The terms and conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program allows for reimbursement of payment for COVID-19 testing and testing related items, COVID-19 treatment or COVID-19 vaccine administration fees as determined by the program for individuals who do not have any health care coverage at the time the services were rendered. Funds provided will not be used to reimburse expenses that have been reimbursed from other sources. Conditions Found During our testing of the internal controls and compliance over the Activities Allowed and Unallowed process, we noted controls that were designed to ensure that HRSA claims reimbursements were submitted for eligible individuals for certain locations associated with a certain urgent care subsidiary were ineffective in certain circumstances. To test the compliance of this process, we tested a total of 45 HRSA claim reimbursement transactions to ensure individuals were uninsured at the time of the service and received an allowable COVID-19 service as per the terms and conditions. We noted for a certain urgent care subsidiary, that 7 of the 8 tested claims were not eligible for reimbursement as the individual either did have insurance at the time of service or the claim was already reimbursed from other sources. The HRSA claims reimbursements associated with this certain urgent care subsidiary was $40,150 for the year ending June 30, 2022. The 7 tested claims that were not eligible for reimbursement were $100 each, which total to the $700 of questioned costs. The sample was not intended to be, and was not, a statistically valid sample. This audit finding is reported as the likely questioned costs could possibly exceed the reporting threshold of $25,000. Management is evaluating the total amount to be remitted back to HRSA. Cause The above finding was caused by a lack of adequate training and monitoring at this certain urgent care subsidiary of the personnel tasked with submitting lab requisitions for COVID-19 tests performed.Effect The schedule of expenditures of federal awards is inappropriately stated as of June 30, 2022 because ineligible costs were charged to the program. Questioned Costs $700 Recommendation We recommend that QHS implement procedures and policies to ensure that the individuals included in HRSA claim reimbursements are uninsured at time of service and that the claim has not been reimbursed from other sources. Views of Responsible Officials QHS agrees with the finding and accepts the recommendation.

Program: Provider Relief Fund Federal Agency Name: U.S. Department of Health and Human Services Federal Award Number: N/A Federal Award Year: 2021 – 2022 Federal Assistance Listing Number: 93.498 Compliance Requirement: Other – Inaccurate Reporting on the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of federal awards (Schedule) for the period covered by the entity’s financial statements, which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, CFR 200.303 requires non-Federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately and completely reported on the Schedule. Conditions Found QHS did not have adequate internal controls related to the reporting of expenditures on the Schedule for the Provider Relief Fund. Specifically, QHS did not have a control to reconcile the Provider Relief Funds received and submitted on the Health Resources and Services Administration (HRSA) Provider Relief Fund reporting portal to the amounts reported on the Schedule. As a result, QHS determined that $5,000,000 of Provider Relief Fund expenditures were inadvertently omitted from the June 30, 2022 Schedule. Cause In discussing the conditions with QHS management, they stated it was caused by failure to implement a reconciliation control related to the Provider Relief Funds received and submitted on the HRSA Provider Relief Fund reporting portal to the amounts reported on the SEFA. Effect Failure to establish effective internal controls regarding the financial reporting for the preparation of the Schedule may prevent QHS from completing an audit in accordance with timelines of Uniform Guidance. Questioned Costs Not applicable.Statistical Sample Not applicable. Repeat Finding This finding is not a repeat finding in the immediately prior audit. Recommendation We recommend that QHS implement a system of internal control that is designed and operating effectively to ensure the Schedule is complete and accurate. Views of Responsible Officials QHS agrees with the finding and accepts the recommendation.

Information on Federal Programs U.S. Department of Health and Human Services: CFDA No. 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund; Award Year: 2021 - 2022. Specific Requirements/Criteria The terms and conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program allows for reimbursement of payment for COVID-19 testing and testing related items, COVID-19 treatment or COVID-19 vaccine administration fees as determined by the program for individuals who do not have any health care coverage at the time the services were rendered. Funds provided will not be used to reimbursed expenses that have been reimbursed from other sources. Condition During our testing of the internal controls and compliance over the Activities Allowed and Unallowed process, we noted controls that were designed to ensure that HRSA claims reimbursements were submitted for eligible individuals for certain locations associated with a certain urgent care subsidiary were ineffective in certain circumstances. To test the compliance of this process, we tested a total of 45 HRSA claim reimbursement transactions to ensure individuals were uninsured at the time of the service and received an allowable COVID-19 service as per the terms and conditions. We noted for a certain urgent care subsidiary, that 7 of the 8 tested claims were not eligible for reimbursement as the individual either did have insurance at the time of service or the claim was already reimbursed from other sources. The HRSA claims reimbursements associated with this certain urgent care subsidiary was $40,150 for the year ending June 30, 2022. The 7 tested claims that were not eligible for reimbursement were $100 each, which total to the $700 questioned costs. The sample was not intended to be, and was not, a statistically valid sample. This audit finding is reported as the likely questioned costs could possibly exceed the reporting threshold of $25,000. Management is evaluating the total amount to be remitted back to HRSA. Cause The above finding was caused by a lack of adequate training and monitoring at this certain urgent care subsidiary of the personnel tasked with submitting lab requisitions for COVID-19 tests performed. Effect The schedule of expenditures of federal awards is inappropriately stated as of June 30, 2022 because ineligible costs were charged to the program. Questioned Costs $700 Recommendation We recommend that QHS implement procedures and policies to ensure that the individuals included in HRSA claim reimbursements are uninsured at time of service and that the claim has not been reimbursed from other sources.

Program: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Agency Name: U.S. Department of Health and Human Services Federal Award Number: N/A Federal Award Year: 2021 – 2022 Federal Assistance Listing Number: 93.461 Compliance Requirement: Activities Allowed or Unallowed Criteria The terms and conditions for Participation in the HRSA COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program allows for reimbursement of payment for COVID-19 testing and testing related items, COVID-19 treatment or COVID-19 vaccine administration fees as determined by the program for individuals who do not have any health care coverage at the time the services were rendered. Funds provided will not be used to reimburse expenses that have been reimbursed from other sources. Conditions Found During our testing of the internal controls and compliance over the Activities Allowed and Unallowed process, we noted controls that were designed to ensure that HRSA claims reimbursements were submitted for eligible individuals for certain locations associated with a certain urgent care subsidiary were ineffective in certain circumstances. To test the compliance of this process, we tested a total of 45 HRSA claim reimbursement transactions to ensure individuals were uninsured at the time of the service and received an allowable COVID-19 service as per the terms and conditions. We noted for a certain urgent care subsidiary, that 7 of the 8 tested claims were not eligible for reimbursement as the individual either did have insurance at the time of service or the claim was already reimbursed from other sources. The HRSA claims reimbursements associated with this certain urgent care subsidiary was $40,150 for the year ending June 30, 2022. The 7 tested claims that were not eligible for reimbursement were $100 each, which total to the $700 of questioned costs. The sample was not intended to be, and was not, a statistically valid sample. This audit finding is reported as the likely questioned costs could possibly exceed the reporting threshold of $25,000. Management is evaluating the total amount to be remitted back to HRSA. Cause The above finding was caused by a lack of adequate training and monitoring at this certain urgent care subsidiary of the personnel tasked with submitting lab requisitions for COVID-19 tests performed.Effect The schedule of expenditures of federal awards is inappropriately stated as of June 30, 2022 because ineligible costs were charged to the program. Questioned Costs $700 Recommendation We recommend that QHS implement procedures and policies to ensure that the individuals included in HRSA claim reimbursements are uninsured at time of service and that the claim has not been reimbursed from other sources. Views of Responsible Officials QHS agrees with the finding and accepts the recommendation.

Program: Provider Relief Fund Federal Agency Name: U.S. Department of Health and Human Services Federal Award Number: N/A Federal Award Year: 2021 – 2022 Federal Assistance Listing Number: 93.498 Compliance Requirement: Other – Inaccurate Reporting on the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of federal awards (Schedule) for the period covered by the entity’s financial statements, which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, CFR 200.303 requires non-Federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately and completely reported on the Schedule. Conditions Found QHS did not have adequate internal controls related to the reporting of expenditures on the Schedule for the Provider Relief Fund. Specifically, QHS did not have a control to reconcile the Provider Relief Funds received and submitted on the Health Resources and Services Administration (HRSA) Provider Relief Fund reporting portal to the amounts reported on the Schedule. As a result, QHS determined that $5,000,000 of Provider Relief Fund expenditures were inadvertently omitted from the June 30, 2022 Schedule. Cause In discussing the conditions with QHS management, they stated it was caused by failure to implement a reconciliation control related to the Provider Relief Funds received and submitted on the HRSA Provider Relief Fund reporting portal to the amounts reported on the SEFA. Effect Failure to establish effective internal controls regarding the financial reporting for the preparation of the Schedule may prevent QHS from completing an audit in accordance with timelines of Uniform Guidance. Questioned Costs Not applicable.Statistical Sample Not applicable. Repeat Finding This finding is not a repeat finding in the immediately prior audit. Recommendation We recommend that QHS implement a system of internal control that is designed and operating effectively to ensure the Schedule is complete and accurate. Views of Responsible Officials QHS agrees with the finding and accepts the recommendation.