In my opinion, if it was reported to HUD, then there is nothing else to have a finding on. The only exception would be if the deficiency was so bad that it required additional work on your part. Other wise, there is nothing more to report. However, it still is an item to report under the schedule of prior audit findings. There it will be listed as a finding from an oversight agency.
What do you mean by “prior” audit findings? This happened in 2017. So I assume you mean it’s a current audit finding and we need to list it as a finding from an oversight agency? I don’t think we’ve ever done that before, even though we’ve had 1 or 2 deficiency issues.
Also, can you please clarify? Is it “higher than level g” or level g and higher? I seem to remember from somewhere that a level g needs to be reported too, but when I was looking for clarification, only thing I found was something that said higher than level G. I can’t find where I found that wording either or I’d send to you.
From Les:
Bruce, when a supervising entity comments on the client’s compliance with regulations by issuing a report, the receipt of that report must be acknowledged in the schedule of prior audit findings – even if it is in the current year. That is the requirement of the HUD Audit Guide. It goes in either section 2 or 3 depending on the nature of the review.
The “G”level requirement is included in the handbook and in the Regulatory Agreement. Findings below that are automatically required to be reported by the client.
From client:
Sorry, I’m not sure I understand – must be the late hour.
This deficiency was part of the regular survey, so they’re not “issuing a report” any differently than every other nursing home in the country for which no finding is disclosed. Unless it’s the fact that they have the high deficiency that makes it into a comment which requires the finding from oversight agency. All facilities always have some sort of deficiency on their surveys, just not usually “G” level, but the G only seems to require immediate notification.
I think you’re saying that a G level finding is not required, only below that, correct?
From Les:
The fact that the agency issued a finding is noted only in the Schedule of Prior Audit Findings. It affects your risk assessment. If the entity does not address these issues, then they get worse. Then is could be a normal finding for you in the schedule of findings and questioned costs. The “G” level issue just means that HUD had to be notified of the finding that was issued. Failure to notify HUD or the lender if a “G” level issue is a finding independent of the actual issue. It is just failure to report.
Les