Single Audit Requirement for Provider Relief Funds; Update on HHS

In response to the pandemic, Congress passed the CARES Act and several other pieces of legislation that created various relief funds to help organizations navigate the impact of COVID-19. For health care providers, medical practices, and other related organizations, who received Provider Relief Funds (PRF), this uninsured fund comes with a unique set of compliance, auditing, and reporting requirements that must be met by recipient organizations.

On January 15, 2021, the U.S. Department of Health & Human Services (HHS) released updated guidance on the Provider Relief Fund reporting requirements. In addition to the many reporting requirements that providers will need to complete, health care providers who received more than $750,000 in federal awards from the Provider Relief Funds (PRF) may be subject to a Single Audit or a program-specific audit.

Lurie advisors are closely monitoring the ongoing developments with the HHS and are following the latest guidance from the AICPA. The following is an overview, but please contact our team before acting on any of the information contained in this update.

What Is the Latest Guidance on the Single Audit Requirement?

According to the AICPA, “there are no new substantive updates to report for PRF. In response to our recent attempts to set up a follow-up meeting with staff of the U.S. Department of Health and Human Services (HHS), they responded that they are still considering all of the questions and issues we raised previously and are working to refine their strategy and plan for additional guidance. So, for now, December 31, 2020, fiscal year-end and later single audits including PRF and for-profit audits of PRF funding continue to be on hold.”

How Is the Timing of Reporting Different Between the HHS Portal and the Single Audit?

On January 15, the Health & Human Services Department announced that it is pushing back the date for PRF recipients to begin reporting on their use of PRF funds, originally due February 15, 2021. No new deadline has been established.

It is our understanding that providers will not be able to move forward with a Single Audit or program specific audit until the HHS reporting in the portal has been completed.

What To Do Now? Contact Your Lurie Advisor

All recipients of funding from these new programs under the CARES Act should be in constant contact with their accountants for guidance and updates.  There has been a lot of anxiety and misinformation around the vague requirements. We want to work with each Practice to determine whether any action is required at this time. We will continue to keep you informed as changes occur in the Single Audit environment, including new timelines. Please check our website for the latest updates.

The Healthcare Practice Group at Lurie is available to help you navigate through this topic and help with any other questions you may have. Contact us for more information. 

Disclaimer:

This article is for your general education and does not create a client relationship or any service engagement between you and Lurie LLP. The content of this article is based on the best information available, but official guidance, rules, laws and/or updates may change and become out of date. Please contact your Lurie advisor before acting on any of the information contained in this article.

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