Alert

Important Changes to Single Audit Reporting Requirements for Provider Relief Fund Recipients

July 21, 2021

In another key development within the Provider Relief Fund (“PRF”) program set forth for healthcare providers, the U.S. Department of Health and Human Services (HHS) recently announced new single audit reporting requirements pertaining to the program.

The major change affects fund recipients with fiscal year ends (“FYEs”) of December 31, 2020, through June 29, 2021, requiring a single audit. PRF will be excluded from the Schedule of Expenditure of Federal Awards (“SEFA”) in the scope of single audits for these entities. This change reflects the effort to align with HHS reporting dates.

Previous Guidance New Guidance
  • Single audits of December 31, 2020, and later fiscal year ends (FYEs) that included PRF funding did not have to report
  • Single audits of nonfederal entities with FYEs ending on December 31, 2020, through June 29, 2021, do not have to report
  • June 30, 2021, and later FYEs do have to report

Single audits of nonfederal entities with PRF funding that have previously been on hold can now be completed. This new guidance supersedes previous guidance in the 2020 OMB Compliance Supplement Addendum which had stated that PRF was to begin being reported on SEFAs for December 31, 2020, and later FYEs.

As previously posted, the reporting requirements are as follows:

Period Payment Received Period
(Payments Exceeding $10,000 in Aggregate Received)
Deadline to Use Funds Reporting Time Period
Period 1 April 10, 2020 to June 30, 2020 June 30, 2021 July 1, 2021 to September 30, 2021
Period 2 July 1, 2020 to December 31, 2020 December 31, 2021 January 1, 2022 to March 31, 2022
Period 3 January 1, 2021 to June 30, 2021 June 30, 2022 July 1, 2022 to September 30, 2022
Period 4 July 1, 2021 to December 31, 2021 December 31, 2022 January 1, 2023 to March 31, 2023

The HHS is taking an approach to link SEFA reporting for PRF to the PRF Reporting Portal. Therefore, reporting of PRF on the SEFA will be as follows:

  • For FYEs of June 30, 2021, through December 30, 2021, recipients are to report on the SEFA, the total expenditures and/or lost revenues from the Period 1 report submission to the PRF Reporting Portal.
  • For FYEs of December 31, 2021, through June 29, 2022, recipients are to report on the SEFA, the total expenditures and/or lost revenues from both the Period 1 and Period 2 report submissions to the PRF Reporting Portal.
  • For FYEs on or after June 30, 2022, SEFA reporting guidance related to Periods 3 and 4 will be provided at a later date.

Cherry Bekaert’s Healthcare team continues to stay abreast of updates and new guidance set forth by HHS and the AICPA’s Governmental Audit Quality Center. Contact us today with questions related to your organization’s PRF reporting and audit requirements.