Provider Relief Funds and Uniform Guidance Audits
On July 22, 2020, the Department of Human Health Services added guidance under the Provider Relief Fund General Information (FAQs) section of its website concerning the applicability of Single Audits to Provider Relief Fund payments indicating that these funds are subject to Single Audit requirements under what is referred to as the Uniform Guidance. Providers will need to engage a firm to perform these audits if annual federal fund expenditures are equal to or above $750,000 a year in total. Providers who receive less than $750, 000 in relief fund moneys should exercise caution as they may still be required to have a Single Audit if they have other federal expenditures, which bring the total above the $750,000 threshold. Please contact your local Marcum Healthcare Advisor for more information and guidance.
The two new FAQs are shown in their entirety below.
Are Provider Relief Fund payments subject to Single Audit requirements under the UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR HHS AWARDS (45 CFR Part 75)? (Added 7/22/2020)
Yes. Provider Relief Fund General and Targeted Distribution payments and Uninsured Testing and Treatment reimbursement payments are required to be included in determining if a recipient organization, other than commercial (for profit) organizations, is required to have an audit in accordance with 45 CFR Part 75, Subpart F (i.e., reported annual total federal fund expenditures equal to or above $750,000).
Audit reports must be submitted to the Federal Audit Clearinghouse electronically at https://harvester.census.gov/facides/Account/Login.aspx.
Are commercial organizations that receive Provider Relief Fund payments required to have a Single Audit in conformance with the requirements under 45 CFR 75 Subpart F? (Added 7/22/2020)
Commercial organizations that receive $750,000 or more in annual federal awards have two options: 1) a financial audit conducted in accordance with Generally Accepted Government Auditing Standards (45 CFR 75.216) or 2) a Single Audit in conformance with the requirements under 45 CFR 75 Subpart F.
Provider Relief Fund payments are required to be included in determining if a recipient that is a commercial (for profit) organizations is required to have an audit in accordance with 45 CFR §75.501 (i.e., reported annual total federal funds received equal to or above $750,000). Audit reports of commercial entities are to be submitted directly to the U.S. Department of Health and Human Services, Audit Resolution Division at https://AuditResolution@hhs.gov.