The financial assistance received by many healthcare organizations in 2020 was not free of compliance requirements. As most of you know by now, The Department of Health and Human Services (HHS) is requiring the recipients of payments in excess of $10,000 to report back to HHS and the Health Resources and Services Administration (HRSA) on their use of the funds. HHS originally set February 15, 2021 as the first deadline for submission, but in late December Congress passed another $3 billion in funding and HHS has been working to amend the original reporting requirements and deadlines so that recipients have ample time to respond appropriately.
One requirement and deadline that is clear is the requirement to report the use of these Provider Relief Funds (PRF) and payments for Uninsured Testing and Treatment on the recipients Statement of Federal Expenditures (SEFA) if the recipient meets the Office of Management and Budget (OMB) reporting threshold. If a Recipient receives at least $750,000 in total federal expenditures (COVID related funds + any other federal funds received during the year), the entity is required to have a single audit consistent with 45 CFR Part 75, Subpart F (“Single Audit”). This requirement applies to non-federal entities and commercial organizations.
“The receipt of the Provider Relief Funds in 2020 will require many organizations to receive their first Single Audit.”
In December 2020, OMB released a Compliance Supplement Addendum to address, in part, the Single Audit Requirement for COVID Federal Fund Expenditures under CFDA #93.498 and COVID Testing for the Uninsured covered under CFDA #93.461, as well as audit requirements applicable to for-profit entities.
The Applicable Compliance Requirements are:
A – Activities Allowed or Unallowed
B – Allowable Costs/Cost Principles
L – Reporting
Most organizations should not have any difficulty meeting these requirements if they spend some time understanding the compliance supplement.
HHS and OMB are continuously providing new guidance and amending or clarifying existing guidance. The audit team at The Health Group and Gray, Griffith & Mays monitor these developments and will provide any significant information on a future update. Please do not hesitate to reach out to our team should you have any questions or concerns.