Provider Relief Fund Single and Program Audit Update

UPDATE: Provider Relief Fund Single and Program Audits are no longer applicable for year ends before June 30, 2021.

On July 15, 2021, the U.S. Department of Health and Human Services (“HHS”) issued updated Frequently Asked Questions (“FAQs”) in regards to Single and Program Audit and Schedule of Expenditures of Federal Awards (“SEFA”) reporting for the Provider Relief Funds (“PRF”). The Governmental Audit Quality Center (“GAQC”) also issued GAQC Alert #429 on July 16, 2021 to communicate these changes and to note confirmation with HHS that this guidance supersedes previous guidance as issued in the 2020 Office of Management and Budget (“OMB”) Compliance Supplement.

HHS issued this guidance for reporting on the SEFA to be tied to the reporting in the HHS PRF reporting portal. The key to the updated guidance is that PRF payments will not be included on the SEFA for entities with fiscal year ends on December 31, 2020 through June 29, 2021. Instead, SEFA reporting will begin with entities with year ends of June 30, 2021 and later.

Below is a chart summary of when expenditures and lost revenue will be included on an entity’s SEFA.

Furthermore, the 2021 OMB Compliance Supplement will be issued with additional guidance on these reporting periods and will include a detailed list of key line items in the PRF reporting portal that auditors will be required to test.

Key takeaway: PRF Single and Program Audits are no longer applicable for year ends before June 30, 2021. Entities who would have been required to undergo a Program or Single Audit by September 30, 2021 will now include the expenditures and lost revenue on reports after their 2021 year end and will be required to undergo the Single or Program Audit within the sooner of 30 days of their 2021 financial statement issuance or 9 months after year end (by September 30, 2022).