HHS updates guidance on PRF single audit timing and amounts to be reported on the SEFA

On July 15, 2021, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), released updated guidance within the CARES Act Provider Relief Fund FAQs addressing certain single audit implications relative to the Provider Relief Fund (PRF). Here’s what you need to know about the timing and amounts to be reported on the Schedule of Expenditures of Federal Awards (SEFA).

When are PRF expenditures and lost revenue reported on the SEFA?

The CARES Act Provider Relief Fund FAQs (as of July 15, 2021) state that nonfederal entities are to report PRF expenditures and/or lost revenues on their SEFA for fiscal year-ends (FYEs) ending on or after June 30, 2021. These FAQs supersede the PRF SEFA reporting guidance previously contained within the 2020 Office of Management and Budget (OMB) Compliance Supplement Addendum.

The FAQs clarify that a nonfederal entity’s SEFA reporting of PRF expenditures and/or lost revenues is linked to its report submissions to the recently opened HHS PRF reporting portal as illustrated in the table below. The reporting time periods defined by HRSA in its June 11, 2021 notice of reporting requirements are included below and in our recent article, “It’s time to report! PRF reporting portal opens on July 1, 2021.” 

Based on reporting time periods established for the PRF reporting portal, the timing of SEFA reporting of PRF will be as follows:

• For a FYE of June 30, 2021, and through FYEs of Dec. 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 Dec. 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.

For-profit entity considerations

While the items above relate to not-for-profits and governmental entities, we’re still trying to determine the relevance of the current guidance on for-profit recipients of PRF funding. The time frame for PRF reporting discussed above is anticipated to be consistent for all recipients of PRF; however, there hasn’t been formal HHS communication to confirm this. We’ll continue to watch for the release of new guidance to ensure the latest information is available for your organization.

What actions do I need to take?

While the latest FAQs clarify that PRF will not be subject to single audit until FYEs ending on June 30, 2021 (at the earliest), organizations will still need to evaluate whether they have a single audit requirement for FYEs ending prior to June 30, 2021. Even with the exclusion of PRF from the SEFA until June 30, 2021, some organizations may still require a single audit if total federal expenditures exceed $750,000 during the fiscal year. The significant increase in COVID-19 funding, in new and existing awards, may result in the organization exceeding the single audit threshold. In a previous article, “COVID-19 funding impact on single audits: Key questions and answers,” we provided a refresher on determining when a single audit is required. This article also includes an outline of new federal programs under which COVID-19 funding was provided (at the time of the article) and whether these funds were subject to single audit.

As you plan for your single audit, please be mindful of its due date. While OMB’s memorandum M-21-20, as noted in the table below, granted several extensions, it isn’t applicable to all fiscal year-ends. 

To ensure a smooth(er) single audit, below are few key actions you should begin today:

• Accumulate all sources of funding and associated grant agreements.
• Prepare your organization’s SEFA and assess the need for a single audit.
• Document your conclusions for qualified expenses and calculations of lost revenue (in the case of PRF) as well as the relevant guidance used when conclusions were made.
• Engage a qualified auditor experienced in performing single audits and begin planning discussions.

The increase in funding to combat the COVID-19 pandemic has resulted in many complexities. Whether you’re preparing for your first or not, don’t go at it alone. We’re here to help.

Want to learn more about single audits?

Check out our upcoming webinar and relevant articles:

• Caution: An influx of federal funds comes with increased risks for organizations
• Top three things to consider if you've received COVID-19 funding
• COVID-19 funding impact on single audits: Key questions and answers