Provider Relief Funds included in audit determination, HHS says

Provider Relief Fund payments are required to be included in the federal funding that determines whether nonfederal entities meet the $750,000 threshold for single audit requirements and whether for-profit entities are required to meet audit requirements, the U.S. Department of Health and Human Services (HHS) announced Wednesday.

Created by the Coronavirus Preparedness and Response Supplemental Appropriations Act, P.L. 116-123, the Provider Relief Fund has provided funding to hospitals and other health care providers that are nonfederal entities (such as states, local governments, and not-for-profits), as well as to for-profit entities.

In FAQ guidance posted to its website, HHS stated that Provider Relief Fund payments as well as Uninsured Testing and Treatment reimbursement payments are required to be included in determining annual total federal fund expenditures of nonfederal entities. If the total federal fund expenditures are at least $750,000, the entity is required to have a single audit in accordance with 45 C.F.R. Part 75, Subpart F, according to the FAQ.

For-profit commercial organizations are required to include Provider Relief Fund payments in determining whether they are required to have an audit in accordance with 45 C.F.R. Section 75.501. Commercial organizations that receive at least $750,000 in annual federal awards have two options to meet the audit requirement:

• A financial audit conducted in accordance with generally accepted government auditing standards (as further detailed in 45 C.F.R. Section 75.216), or
• A single audit in accordance with 45 C.F.R. Part 75, Subpart F.

HHS also confirmed that organizations can receive an extension to the submission deadline for their upcoming single audits because the Office of Management and Budget (OMB) has provided certain flexibilities as a result of the pandemic.

More information is available on the OMB website, and questions about extensions can be emailed to the Health Resources & Services Administration’s Division of Financial Integrity at SARFollowup@hrsa.gov.

The AICPA Governmental Audit Quality Center (GAQC) also has addressed the HHS decision regarding the Provider Relief Fund payments in GAQC Alert #411. See other GAQC COVID-19 single audit resources at the GAQC Uniform Guidance Resources page.

— Ken Tysiac (Kenneth.Tysiac@aicpa-cima.com) is the JofA’s editorial director.