Health care providers have received billions of dollars in relief fund payments from the Provider Relief Fund created by the CARES Act signed into law in March. Providers that received Relief Fund payments are required to comply with certain auditing and reporting requirements as specified by the Department of Health and Human Services (“HHS”). On January 15, 2021, HHS released updated post-payment reporting requirements for the Provider Relief Funds (PRF). Providers that expended more than $750,000 in Relief Fund payments and other federal awards will be subject to the HHS single audit process.
Single Audit Requirements
HHS stated Provider Relief Fund General and Targeted Distribution payments (CFDA 93.498) and Uninsured Testing and Treatment reimbursement payments (CFDA 93.461) to non-Federal entities are Federal awards and must be included in determining whether an audit in accordance with 45 CFR Part 75, Subpart F is required (i.e., annual total federal awards expended are $750,000 or more). The Office of Inspector General (“OIG”) has signaled that it will audit to confirm that Providers are complying with federal requirements and the terms and conditions for reporting and expending the Relief Fund payments
The purpose of the Single Audit is to ensure that entities that expended $750,000 in federal funds engage an outside auditor to test internal controls and compliance in order to provide an opinion on the entity’s compliance with the requirements of retaining the federal funds. The auditors will issue a report related to the Single Audit that identifies any reportable findings or questioned costs. So, plan now to ensure you have appropriate internal controls related to federal guidelines.
The Office of Management and Budget (“OMB”) released a Compliance Supplement Addendum in December 2020 to address, in part, the Single Audit requirement for COVID Federal Fund Expenditures. This supplement states that Provider Relief Funds will be included in your schedule of expenditures of federal awards and audited under the Uniform Guidance in a fiscal year ending on or after December 31, 2020. Entities with fiscal years ending on or before December 30, 2020 will report no PRF expenditures including no lost revenue. This Compliance Supplement Addendum, along with the Compliance Supplement issued in August 2020, describes the requirements and process for the Single Audit.
The COVID-19 public health emergency continues, the reporting and auditing obligations are starting, and Providers need to:
- Continue to prepare information for the Relief Fund Reporting and monitor updates on guidance and reporting – see the latest Frequently Asked Questions (FAQs)
- Determine if you are subject to the Single Audit Requirement, review the process, prepare for the audit and meet the reporting deadlines.
- Monitor the OIG Relief Fund reviews and enforcement actions.
We are here to support you through the complexities of the COVID-19 Funding. Whether this is your first Single Audit or not, we can help you with the Uniform Guidance and Compliance Reporting as well as Develop Internal Controls.