On July 15, 2021, HHS released new guidance on the Single Audit requirements for recipients of HHS Provider Relief Funds.
Provider Relief Fund expenditures and/or lost revenues will be excluded from the scope of single audits of non-federal entities with fiscal years ended December 31, 2020 through June 29, 2021.
Non-federal entities will include Provider Relief Fund expenditures and/or lost revenues on their Schedule of Expenditures of Federal Awards (SEFA) for fiscal year ends (FYEs) ending on or after June 30, 2021. See the table below:
Therefore, a recipient entity with a December year-end will report on its 2021 calendar year SEFA the total expenditures and/or lost revenues from both the Period 1 and Period 2 report submissions to the Provider Relief Fund Reporting Portal.
Please note that the above guidance released on July 15, 2021 by HHS is for non-federal entities. However, on July 27, 2021, the AICPA did confirm that the time frame for the SEFA reporting discussed above is anticipated to be consistent for all recipients of Provider Relief Funds (including for-profit entities); however, there has not yet been a formal HHS communication to confirm this.
HHS is still requiring for-profit entities that report on its SEFA expenditures of federal awards (including Provider Relief Funds) of $750,000 or more to get either a single audit or GAGAS financial audit (including a program specific audit). However, those audits cannot be completed until after March 31, 2022 and currently would have a submission deadline of September 30, 2022.
We will continue to watch for the release of new guidance to ensure the latest information is available for your organization.