PRB Reporting and Auditing FAQ
Download all Provider Relief Fund FAQs (PDF - 561 KB)
Auditing and Reporting Requirements
No. The Reporting Entity may not amend its report after the reporting period has passed.
Yes. Due to the cumulative nature of lost revenues, any lost revenues adjustments may be made in subsequent reporting periods. If an unallowable expense is “replaced” by unreimbursed lost revenues for use of funds purposes, the Reporting Entity should ensure that the lost revenues reported in subsequent reports are deducted to avoid “double dipping.” Reporting Entities should maintain appropriate documentation to support the deduction from the report.
HRSA does not set requirements or provide extensions for the submission of the Single Audits. The due date for an Audit is the earlier of 30 days after receipt of the auditor’s report(s), or 9 months after the end of the audit period, which is likely your organization’s fiscal year end. (45 CFR 75.512).
Under the Stafford Act, the following were declared as major disaster areas: Puerto Rico (September 18, 2022), Alaska (September 23, 2022), Florida (September 29, 2022), South Carolina (September 29, 2022) and North Carolina (October 1, 2022). Consistent with these declarations, OMB has granted a six-month extension for all single audits that cover recipients in the affected areas and have due dates between September 18, 2022 and December 31, 2022.
If you have questions about this extension or want to inform HRSA you will be taking advantage of this flexibility, please email HRSA's Division of Financial Integrity at PRFAudits@hrsa.gov. If you have questions about the Single Audit for Provider Relief Fund, please email your questions to ProviderReliefContact@hrsa.gov.
Yes. Both commercial organizations and non-federal entities are granted a six-month extension to the submission of audits that have a fiscal-year end through June 30, 2021. As a reminder, audits are due 30 calendar days after receipt of the audit report or nine months after the end of the audit period – whichever is earlier. On March 19, 2021, the Office of Management and Budget (OMB) Memo (M-21-20 (PDF - 372 KB)) extended the deadline for Single Audit submissions to six months beyond the normal due date, and on October 28, 2021, HHS granted the same extension to commercial organizations.
If you have questions about this extension or want to inform HRSA you will be taking advantage of this flexibility, please email HRSA's Division of Financial Integrity at PRFaudits@hrsa.gov.
If you have questions about the audit in accordance with 45 CFR 75.501 for Provider Relief Fund payments, please email your questions to ProviderReliefContact@hrsa.gov.
Yes, the non-profit corporation can include the expenditures of federal awards of its for-profit subsidiary in its Single Audit. Federal regulations at 45 CFR § 75.501 or “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards” (Uniform Guidance) permits a for-profit subsidiary to be included in the Single Audit, as long as the for-profit subsidiary’s operations are included in the consolidated financial statements and program expenditures are included in the Schedule of Expenditure of Federal Awards (SEFA). The inclusion of the for-profit subsidiary in the consolidated entity’s Single Audit would meet the for-profit entity’s responsibility for an audit under 45 CFR § 75.501(i).
Yes, the for-profit entity can have one financial-related audit of all HHS awards that incorporates all entities. 45 CFR § 75.501(i) audit requirements permit this approach.
Yes, multiple for-profit entities under common control that issue combined financial statements can have one financial-related audit of all HHS awards that incorporates each of the entities. 45 CFR § 75.501(i) audit requirements permit this approach.
Similar to non-federal entities, for-profit entities will include Provider Relief Fund expenditures and/or lost revenues on their SEFAs or other schedules for fiscal year ends (FYEs) ending on or after June 30, 2021.
Similar to non-federal entities, a for-profit entity’s SEFA (or other schedules) is linked to its report submissions to the Provider Relief Fund Reporting Portal. Therefore, the timing of reporting of Provider Relief Fund payments on the SEFA (or other schedules) will be as follows:
- For FYE’s of June 30, 2021 through FYEs of December 30, 2021, recipients must report on the SEFA (or other schedules) the total expenditures and/or lost revenues included in the Period 1 report submission to the Provider Relief Fund Reporting Portal.
- For FYE’s of December 31, 2021 through FYEs of June 29, 2022, recipients must report on the SEFA (or other schedules) the total expenditures and/or lost revenues included in both the Period 1 and Period 2 report submissions to the Provider Relief Fund Reporting Portal.
For FYEs on or after June 30, 2022, reporting guidance for the SEFA or other schedules related to Period 3 and Period 4 will be provided at a later date.
Non-federal entities will include Provider Relief Fund expenditures and/or lost revenues on their SEFAs for fiscal year ends (FYEs) ending on or after June 30, 2021. Please refer to the 2021 OMB Compliance Supplement, available at https://www.whitehouse.gov/wp-content/uploads/2021/08/OMB-2021-Compliance-Supplement_Final_V2.pdf (PDF - 18 MB), for additional information.
A non-federal entity’s SEFA reporting is linked to its report submissions to the Provider Relief Fund Reporting Portal. Therefore, the timing of SEFA reporting of Provider Relief Fund payments will be as follows:
- For a FYE of June 30, 2021, and through FYEs of December 30, 2021, recipients are to report on the SEFA, the total expenditures and/or lost revenues from the Period 1 PRF report submission to the PRF reporting portal.
- For a FYE of December 31, 2021, and through FYEs of 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 PRF report submissions to the PRF reporting portal.
- For FYEs on or after June 30, 2022, SEFA reporting guidance related to Period 3 and Period 4 will be provided at a later date.
No. HHS included requirements on how recipients of the SNF and Nursing Home Infection Control Distribution payments will report on these funds in the June 2021 Post-Payment Notice of Reporting Requirements. Recipients of this funding will be able to submit a consolidated report that distinguishes use of SNF and Nursing Home Infection Control Distribution funds from use of other General and Targeted Distribution payments.
The only guidance HHS provides to auditors is through the Office of Management and Budget Compliance Supplement. Non-Federal Entities subject to Single Audit requirements can find guidance in the 2020 Compliance Supplement Addendum, which is available at https://www.whitehouse.gov/wp-content/uploads/2020/12/2020-Compliance-Supplement- Addendum_Final.pdf (PDF - 1 MB) and in the forthcoming 2021 Compliance Supplement. The applicable Assistance Listings numbers include 93.498 [Provider Relief Fund] and 93.461 [HRSA COVID- 19 Uninsured Program].
Commercial organizations that expend $750,000 or more in annual awards have two options under 45 CFR 75.216(d) and 75.501(i): 1) a financial related audit of the award or awards conducted in accordance with Generally Accepted Government Auditing Standards; or 2) an audit in conformance with the requirements of 45 CFR 75.514 (Single Audit). Provider Relief Fund General and Targeted Distribution payments (93.498) and Uninsured Testing, Treatment, and Vaccine Administration reimbursement payments (93.461) must be included in determining whether an audit in accordance with 45 CFR Subpart F is required (i.e., annual total awards expended are $750,000 or more). Audit reports of commercial organizations must be submitted via email to HRSA’s Division of Financial Integrity at PRFaudits@hrsa.gov.
RHCs that were issued a payment with the descriptor “HHSPAYMENT” or “COVID*RuralHealthTestingPmt*HHS.GOV” on or around May 20, 2020, June 9, 2020, December 7, 2020, and/or January 20, 2021, received these payments as part of RHC COVID-19 Testing Program. HHS provided $49,461.42 for each eligible RHC with a unique CMS Certification Number (CCN) associated with an eligible Tax Identification Number (TIN). TIN organizations must report data associated with COVID-19 testing payments on the Rural Health Clinic COVID-19 Testing Report Portal available at https://www.rhccovidreporting.com/. For additional information, please visit HRSA’s website at https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questions#rhc. If you have additional questions please email RHCcovidreporting@narhc.org for technical assistance.
Provider Relief Fund General and Targeted Distribution payments (CFDA 93.498) and Uninsured Testing and Treatment reimbursement payments (CFDA 93.461) to non-Federal entities are Federal awards and must be included in determining whether an audit in accordance with 45 CFR Part 75, Subpart F is required (i.e., annual total federal awards expended are $750,000 or more).
Audit reports must be submitted electronically to the Federal Audit Clearinghouse.
(Requirements for audit of payments to commercial organizations are discussed in a separate question.)
Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision. For all providers who attest to receiving a Provider Relief Fund payment and agree to the Terms and Conditions (or retain such a payment for more than 90 days), HHS is posting the names of payment recipients and their payment amounts on its public website here. HHS is also working with the Department of Treasury to reflect the aggregate total of each recipient's attested to Provider Relief Fund payments on USAspending.gov. Posting these data meets the reporting requirements of the CARES Act. See Appendix A of OMB Memo M-20-21 [Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)].
However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient's use of its PRF money. For more information on these requirements.