Independent Audit Requirements for Provider Relief Fund Payments
Recipients that spend a total of $750,000 or more in federal funds, including Provider Relief Fund (PRF) payments and other federal financial assistance, during their fiscal year are subject to Single Audit requirements, as set forth in the regulations at 45 Code of Federal Regulations (CFR) § 75 Subpart F. This includes organizations subject to the Single Audit Act and commercial organizations. The report is due the earlier of 30 calendar days after the receipt of the audit or 9 months after the fiscal year.
Recipients who have not submitted their audit as of March 19, 2021 that have fiscal year ends (FYE) through June 30, 2021 may delay their submission by 6 months beyond the normal due date per Office of Management and Budget (OMB) Memo (M-21-20) (PDF - 372 KB).
- Definitions of Entities per 45 CFR 75
- Audit Requirement (Non-federal entities)
- Audit Requirement (Commercial Organizations)
- HRSA Audits
- Verifying Payment Amounts
Definitions of Entities per 45 CFR 75.2
- Non-Federal entity means a state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries out a federal award as a recipient or subrecipient. Non-federal entities must have a Single Audit conducted in accordance with 45 CFR § 75.514 that must be submitted electronically to the Federal Audit Clearinghouse.
- Commercial organization means an organization, institution, corporation, or other legal entity, including, but not limited to, partnerships, sole proprietorships, and limited liability companies, that is organized or operated for the profit or benefit of its shareholders or other owners. The term includes small and large businesses and is used interchangeably with “for profit organization.”
Audit Requirement (Non-federal entities)
- Non-federal entities must have a Single Audit conducted in accordance with 45 CFR § 75.514 or program-specific audit conducted in accordance with 45 CFR § 75.507.
- Reports must be submitted electronically to the Federal Audit Clearinghouse.
- The 2022 Compliance Supplement (PDF - 20 MB)1 provides information for auditors on the key compliance requirements and clarification on when Providers should report PRF payments on the Schedule of Expenditures of Federal Awards (SEFA).2
Reporting Funds in the Schedule of Expenditures of Federal Awards (SEFA)
|Reporting Period||Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)||Deadline to Use Funds||PRF Portal Reporting Time Period||Fiscal Year Ends (FYEs) to Include each PRF Period on the Schedule of Expenditures for Federal Awards (SEFA) Reporting|
|Period 1||April 10, 2020 to June 30, 2020||June 30, 2021||July 1, 2021 to September 30, 2021||FYE’s of June 30, 2021 through June 29, 2022|
|Period 2||July 1, 2020 to December 31, 2020||December 31, 2021||January 1, 2022 to March 31, 2022||FYE’s of December 31, 2021 through FYEs June 29, 2022|
|Period 3||January 1, 2021 to June 30, 2021||June 30, 2022||July 1, 2022 to September 30, 2022||Guidance will be included in 2022 Compliance Supplement|
|Period 4||July 1, 2021 to December 31, 2021||December 31, 2022||January 1, 2023 to March 31, 2023||Guidance will be included in 2022 Compliance Supplement|
|Period 5||January 1, 2022 to June 30, 2022||June 30, 2023||July 1, 2023 to September 30, 2023||FYEs of June 30, 2023 guidance will be included in 2023 Compliance Supplement|
12021 Compliance Supplement Addendum (PDF - 18 MB)
Audit Requirement (Commercial Organizations)
Commercial organizations have two options under 45 CFR § 75.216(d) and § 75.501(i):
- A financial related audit of the award or awards conducted in accordance with Generally Accepted Government Auditing Standards; or
- An audit in conformance with the requirements of 45 CFR § 75.514 - Single Audit. Audit reports of commercial organizations must be submitted via email to HRSA’s Division of Financial Integrity at PRFaudits@hrsa.gov. HRSA defers to the auditor and the provider of commercial organizations to make a determination as to the basis of accounting that will be sufficient to complete a financial related audit in accordance with Government Auditing Standards under 45 CFR § 75.501.
Any recipients identified as having provided inaccurate information to HHS will be subject to payment recovery and other legal action. Further, all recipients of PRF payments shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR § 75.302 – Financial Management and 45 CFR § 75.361 through § 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate that recipients used all PRF payments appropriately.
Upon the request of the Secretary, the recipient shall promptly submit copies of such records and cost documentation and the recipient must fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with applicable Terms and Conditions. Deliberate omission, misrepresentation, or falsification of any information contained in payment applications or future reports may be punishable by criminal, civil, or administrative penalties, including but not limited to revocation of Medicare billing privileges, exclusion from federal health care programs, and/or the imposition of fines, civil damages, and/or imprisonment.
Verifying Payment Amounts
To request that HRSA verify the amount and date of payments received from the PRF for auditing purposes, the following information should be sent by the recipient of funds to ProviderReliefContact@hrsa.gov.
- Provider name
- Provider address
- Provider email address associated with PRF payments
- Name and title of business official making the request
- Date range
- Auditor name and contact information
Requests must either come from an email domain associated with the recipient of funding or with the request attached with signature on the recipient’s letterhead authorizing the release of information to the named auditor.