COVID-19: Provider Relief Funds and Uniform Guidance Update

Guidance on the Threshold for Single Audit Requirements

On July 22, the U.S. Department of Health and Human Services (HHS) announced that Provider Relief Fund payments must 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 Provider Relief Fund, created by the Coronavirus Preparedness and Response Supplemental Appropriations Act, P.L. 116-123, 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.

The July 22 guidance posted to the Provider Relief Fund General Information (FAQs) section of its website concerns the applicability of Single Audits to Provider Relief Fund payments. These funds are subject to Single Audit requirements under what is referred to as the Uniform Guidance. 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.

Other details:

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.

Additionally, HHS stated 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.

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