2. 8.4.3. (a) Audit required. 2 Single audit means an audit that . These entities have two options (assuming PRF money is the only federal funding received): A single audit on the . According to the Subpart F-Audits 45 CFR 75.501(a) Visit disclaimer page. The largest source of this funding came from . The single audit conducted under the Single Audit Act, supplemented by other related audits, reviews, and data sources will help identify violations. The entity has complied with applicable laws, regulations, and other . The Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance") has been issued by the Office of Management and Budget (OMB).

On July 22, 2020, HHS updated its guidelines yet again to announce that non-federal entities expending $750,000 or more in Provider Relief Fund money must undergo a single audit for the calendar year. Over the next two years, many entities that have received federal funds, and have incurred expenditures or lost revenue exceeding the $750,000 threshold may require a Single Audit for the first time. In the audit, auditors are required to test compliance over federal awards that the auditor determines to be major programs. HHS/ACF has implemented the Uniform Guidance at 45 CFR 75. OAS also: Any use of funds that violated the provisions of the Act, section 115(a)(1) of PRWORA, the provisions of 45 CFR part 92 or OMB Circular A-87 will be considered to be a misuse of funds. The US Department of Health and Human Services (HHS) released revised reporting requirements; . The CIL must arrange for a financial and compliance audit (single audit) if required by OMB Circular A-133. On July 15, 2021, HHS released new guidance on the Single Audit requirements for recipients of HHS Provider Relief Funds. If you are new to single audit, we have developed a resource, Single Audit Auditee Summary, to learn more about the requirements and how to prepare for a single audit. (PDF), as outlined in the most recent revision of the HHS Poverty Guidelines. New Single Audit Requirement! Information: Office of Management and Budget (OMB) Circular A-133 applies to audits of States, local governments, and non-profit organizations. Non-federal entities will include Provider Latest Guidance on the Single . HHS/ACF has implemented the Uniform Guidance at 45 CFR 75 Visit disclaimer page. If you use all of your PRF funds in 2020 you'll only have to report once on February 15.

Single Audit Requirements. The single audit serves as the single most important way for the federal government to assess the financial health of your organization and your organization's ability to manage federal awards. the Single Audit Act Amendments of 1996; applicable Office of Management and Budget circulars; and other legal, regulatory, and administrative requirements. The audit is conducted under Subpart F of the Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Building on the Single Audit Act of 1984, the 1996 amendments laid out updated audit requirements for organizations and people who receive Federal awards. Based on current information from HHS, provider relief funds are also subject to audit if more than $750,000 has been expended during an entity's fiscal year. If you are delinquent in submitting your single audit, HRSA is required to follow up with your organization and to ensure that the delinquent . HHS has recently confirmed that PRF awards are included in the basis for determining whether an audit requirement was triggered, including for-profit . (b) Single audit. The OMB's 2020 Compliance Supplement will determine which compliance requirements auditors must consider for testing each major program. On July 22, 2020, the Department of Health and Human Services (HHS) updated their Frequently Asked Questions (FAQ) page with important information regarding the applicability of Single Audit requirements for entities receiving Provider Relief Funds under the CARES Act.

This guidance supersedes requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in OMB guidances); Circulars A-89, A-102, and A-133; and the guidance in Circular . Support OMB oversight and assessment of federal award audit requirements. 93 Department of Health and Human Services (HHS) 93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth (Ryan White HIV/AIDS Program Part D Women, Infants . Be clear about what needs to be done and when. PRF dollars are subject to federal compliance audit requirements, which, if you received and expended more than $750,000 in your latest fiscal year, inclusive of PRF and other federal funds received from other sources, will require the involvement of a qualified and experienced audit firm to certify your entity's compliance with the terms of . Other HHS Awards received unless specifically excluded Commercial organizations have three options to meet the HHS for-profit audit requirements. According to ACF, assessing a grantee's implementation of corrective action can be accomplished through using subsequent years' Single Audits, which ACF believes satisfies the objective of recommendation four.

That is, until HHS released a notice of post-payment reporting requirements on July 20, 2020 and three . New Single Audit Requirement! Single Audit Requirements. The delays in the HHS portal launch described above, along with the need for HHS guidance on its expectations for the financial . . On Thursday, July 15, 2021, the Department of Health and Human Services (HHS) released updated auditing and reporting requirements to the Provider Relief Funds (PRF) Frequently Asked Questions (FAQs). These reporting requirements apply to PRF recipients who received one or more payments exceeding $10,000 in the aggregate, but do not apply to the Nursing Home Infection Control . . The LIHEAP law requires that the program be audited every year according to the Single Audit Act requirements. However, HHS has recently informed the GAQC that for-profit entities that expend $750,000 or more of these funds during the entity's fiscal year will be subject to an audit as described in section 75.216 of HHS's adoption of the Uniform Guidance. recommendation and stated it would ensure that the requirements for audit followup are met in accordance with the Uniform Guidance. Single Audit Act audits must also be made available for public inspection. On September 19, 2020, the Department of Health and Human Services (HHS) released guidance establishing the reporting requirements for health care providers that received Provider Relief Fund (PRF) payments. In an effort to help deal with the challenges presented by the . For many for-profit entities, the December 31, 2021, year-end is the first time the HHS audit requirement becomes effective. Many nonprofits face single audits for the first time. Single Audit (2 CFR 200/45 CFR Section 75) Requires an audit of the entity's financial statements under Generally Accepted Government Auditing Standards (GAGAS). The Single Audit must be performed by an independent auditor and the reporting package (which includes the audit report) must be submitted to the Federal Audit Clearinghouse within 30 days after your organization receives the audit report or 9 months from your organization's fiscal year end. An audit is a systematic review or appraisal made to determine whether internal accounting and other control systems provide reasonable assurance of the following: Financial operations are properly conducted. This will also trigger a requirement for the financial statements to be performed under Government Auditing Standards. (a) Audit required. (b) Single audit. There are two reporting options: A financial audit of the use of the awards in accordance with Generally Accepted Government Auditing Standards; or; An audit in compliance with the Single . Yes, the non-profit corporation can include the expenditures of federal awards of its for-profit subsidiary in its Single Audit. Its primary purposes are to: Distribute single audit reporting packages to federal agencies. That the Provider is responsible for payment of any valid audit exceptions found by the Department, HHSC, HHS or the Texas Attorney General's Medicaid Fraud Control Unit (AG-MFCU). Government-mandated shutdowns forced not-for-profit (NFP) organizations to move to a remote environment, restructure their operations, and close doors for many activities.

HHS, through the Health Resources and Services Administration (HRSA), launched the COVID-19 Uninsured Program Portal, a single electronic claims processing system for health care providers for submitting claims for reimbursements for diagnostic testing and treating uninsured individuals. A Single Audit is an audit of a non-federal entity that expends $750,000 or more of federal assistance during its fiscal year. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards is located under 45 CFR Part 75. HHS stated Provider Relief Fund payments and payments for Uninsured Testing and Treatment must be included in determining annual total federal fund expenditures for nonfederal entities ("COVID Federal Fund Exp."). A for-profit organization is required to have a non-federal audit if, during its fiscal year, it expended a total of $750,000 or more under one or more HHS awards (as a direct recipient or . NFPs with fiscal periods ending June 30, 2020 would be the first to potentially undergo these audits. Updated Guidance on SEFA and Single Audit/Financial Related Audit of Funds. The resulting single audit report must be approved by the CIL board and, if necessary, a corrective plan must be developed.

requirements. 1) If you received more than $750,000 in HHS awards, you are required to receive either a Single or program-specific audit (Single Audit) following 45 CFR* Part 75, Subpart F, or Financial-related audit of all HHS awards following Generally Accepted Government Auditing Standards ( GAGAS ). Selection of Auditor Step 1: Plan Carefully. Many nonfederal entities are expected to be subject to Single Audit requirements for the first time as a result of this requirement. Current guidance regarding Schedule of Federal Awards of Federal Assistance (SEFA) and Single Audit/financial related audit of the PRF are now misaligned with the June 11 . Those requirements include the following two options available to for-profit entities that report at least $750,000 in federal awards from HHS in an individual fiscal year: Financial related audit of all HHS awards in accordance with GAGAS, or the "Yellow Book." This will be referred to as a GAGAS financial audit. 45 CFR 75 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards; The HHS Grants Policy Statement; and The most common findings disclosed in single audit reports, HHS Office of Inspector . A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part.

On July 22, 2020, HHS updated its guidelines yet again to announce that non-federal entities expending $750,000 or more in Provider Relief Fund money must undergo a single audit for the calendar year. The last time they were 5% or more was in 1991, according to the WorldatWork 2019/2020 Salary budget Survey. Grants Policy Resources. Single Audit Requirements Single Audit Requirements Policy DFPS, in collaboration with HHS-PCS, is required to apply single audit requirements to subrecipients and recipients that have state or federal cumulative expenditures of $750,000 or more. Federal Agency: HHS For-Profits, NFPs, Governmental Entities Is subject to single audit CFDA: 93.498 Coronavirus Relief Fund ($150B) Federal Agency: Treasury Governmental Entities and Tribes Is subject to single audit CFDA: 21.019 Educational Stabilization Fund ($30.75B) Federal Agency: Education States, Schools, IHE Is subject to single audit Nonprofits that expended $750,000 or more in federal funds in a single fiscal year are subject to the single . HHS/ACF has implemented the Uniform Guidance at 45 CFR 75 . a financial related audit (as defined in the Government Auditing Standards, GPO Stock #020-000-00-265-4) of a particular award in accordance with Government Auditing Standards, in those cases where the recipient receives awards under only one HHS program; or, if awards are received under multiple HHS programs, a financial related audit of all HHS awards in accordance with Government Auditing . Financial reports are timely, fair, and accurately. 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 . CSBG grantees and eligible entities that had not filed their single audits with the Federal Audit Clearinghouse as of March 19, 2020, that have normal due dates from March 30, 2020, through June 30, 2020, may delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR 200.501 Audit . Many of these for-profit health care entities will need such an audit for the first time because these HHS audit requirements apply to entities with $750,000 or more in HHS awards. It supersedes the 2020 Compliance Supplement and its [] 8621 et seq. See below for frequently asked questions: That in accordance with 403.0551 , Texas Government Code, and unless otherwise prohibited by any other law, any payments due to the Provider under this agreement Single Audit Requirements HHS stated 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 . External NIH grantees expending $750,000 or more in Federal funds per year must conduct an annual audit in accordance with the Single Audit Act and 45 CFR part 75. The administrative requirements and cost principles are effective for new awards and to additional funding on existing awards as of December 26, 2014. Household Water Assistance Program's (LIHWAP) terms and conditions on assurances and requirements outlined in the Low Income Household Energy Assistance Act, 42 U.S.C. On 29 . Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR - 200) - Final revised rule streamlining grant management requirements. Planning to hire an external auditor requires time and attention. These audits examine the performance of HHS programs and/or grantees in carrying out their responsibilities and provide independent assessments of HHS programs and operations. In addition to federal Single Audits, some states, including New Jersey and Connecticut, have their own Healthcare. Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period). Audits are to be submitted to the Federal Audit Clearinghouse at the Bureau of Census located at 1201 E. 10th Street, Jeffersonville, Indiana 47132. Audit. These entities have two options (assuming PRF money is the only federal funding received): A single audit on the . 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. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a . Read the . 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 Single Audit, typically performed annually, is intended to ensure an organization is using its federal funds correctly and is in . The single audit requirement kicks in for grantees who spend more than $750,000 in federal dollars in any given year. The coronavirus (COVID-19) pandemic has significantly impacted the way CPAs plan and conduct single audits. Providers who received one or more General and/or Targeted PRF payment (s) exceeding $10,000, in the aggregate, from January 1, 2021 to June 30, 2021 must report on their use of funds in RP3. Ensure recipient compliance with single audit requirements and audit recommendations relating to inadequate P&P; and . We will determine whether claims for COVID-19 diagnostic . For more information about the HHS lost revenues calculation, Phase 3 application process, or single audit resources, please contact our Albany office at (229) 883-7878 or our . The significant increase in COVID-19 funding, in new and existing awards, may result in the organization exceeding the single audit threshold. . The law aimed to streamline the auditing process so that award recipients only have to conduct a single, annual audit instead of conducting multiple audits of individual programs. According to the Subpart F-Audits 45 CFR 75.501 (a) Audit requirements for for-profit (commercial) organizations, including for-profit hospitals, are defined in 45 CFR Part 75.501 (h)-(k) external icon. HHS PROVIDER RELIEF FUND SINGLE AUDIT UPDATE September 30, 2021. Since the establishment of PRF, HHS continued to deliberate whether PRF awards were subject to a single audit, as well as the requirements for for-profit entities included in section 75.216. Uncertainty and new audit requirements; Many health-care clients receiving HHS funding of $750,000 or more will be subject to single audit requirements, perhaps for the first time. At the time of distribution, HHS hadn't released any additional information related to the reporting requirements or clarification on whether providers who attested to payments under the Provider Relief Fund would be subject to Single Audit. a financial related audit (as defined in the Government Auditing Standards, GPO Stock #020-000-00-265-4) of a particular award in accordance with Government Auditing Standards, in those cases where the recipient receives awards under only one HHS program; or, if awards are received under multiple HHS programs, a financial related audit of all HHS awards in accordance with Government Auditing .

In the area of non-federal match, this includes assessing whether the non-federal entity provided the minimum amount of match required, that match allocated was allowable, and . A non-Federal entity that expends $750,000 or more during the non-Federal entity 's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. Audit Requirements Under the Single Audit Act, and 45 CFR Part 75 Subpart F-Audit Requirements , auditors are required to assess internal control and compliance. Singapore's Health Sciences Authority (HSA) From 01 January 2014 to 31 December 2016, FDA, alongside its international partners, participated in a Medical Device Single Audit Program Pilot. The HHS for-profit audit requirements include options for either a single audit (or program-specific audit) or a financial audit under Government Auditing Standards (referred to as a GAGAS financial audit). Single Audit Act Amendments of 1996 Enacted to streamline and improve the effectiveness of audits of federal awards and to reduce the audit burden on states, local governments, and not-for-profit entities Detailed implementation requirements for single audits (both auditee and auditor) contained in regulation Uniform Guidance Current . It is called a single audit because it is a standardized approach used by all federal agencies, covering financial statements and records, expenditures and internal controls, as well as elements specific to the grant itself. The deadline to use funds for Payment Received Period 3 was June 30, 2022. Review the Post-Payment Notice of Reporting Requirements (PDF - 232 KB) Reports must be submitted electronically to the Federal Audit Clearinghouse. There are two main parts of a Single Audit: an audit of the . July 23, 2021 Some confusion was lifted last week for practitioners who perform single audits of health care entities, when the U.S. Department of Health and Human Services (HHS) clarified rules for single audits of nonfederal entities that received pandemic-related assistance from the Provider Relief Fund (PRF). The CIL must comply with the following requirements: The audit must reflect the CIL's fiscal year; Pharmacies that received more than $750,000 in federal funds, including PRF monies, will be subject to single audit requirements. HHS had not previously decided about the for-profit entity audit requirements for the PRF program. If a Recipient receives at least $750,000 in total federal fund expenditures (which included the . July 31, 2021: The final reporting deadline for providers who did not fully expend PRF funds prior to December 31, 2020. 714-668-7370. sshill@bdo.com ANDREA SPETRINI. 75.501 Audit requirements. Over the next two years, many entities who have received PRF exceeding the $750,000 threshold may require an audit for the first time. According to the Office of Management and Budget (OMB), a Single Audit covers the entity's entire operations. 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. Single Audit Single Audit, previously known as the OMB Circular A-133 audit, is an organization-wide financial statement and federal awards' audit of a non-federal entity that expends $750,000 or more in federal funds in one year. Section 75.216), or A single audit in accordance with 45 C.F.R. These audits examine the performance of HHS programs and/or grantees in carrying out their responsibilities and provide independent assessments of HHS programs and operations. 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. OAS also: On August 12, 2021, the Office of Management and Budget (OMB) released the 2021 Compliance Supplement effective for audits of fiscal years beginning after June 30, 2020. These audit requirements would begin in the fiscal or calendar year that an entity expends $750,000 or more in federal awards. Part 75, Subpart F. Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments). Is not subject to single audit Assistance Listing: 59.073 Provider Relief Fund ($175B) Federal Agency: HHS For-Profits, NFPs, Governmental Entities Is subject to single audit Assistance Listing: 93.498 Coronavirus Relief Fund ($150B) Federal Agency: Treasury Governmental Entities and Tribes Is subject to single audit Assistance Listing: 21.019 Single Audit Requirements The Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance") has been issued by the Office of Management and Budget (OMB). Audit Partner and Practice Leader. Maintain a public database of completed audits. The good news: many single audits of non-federal entities can now be finalized, as PRF may be outside the scope of the single audit depending on the recipient's fiscal year-end (FYE). 1 Most grantees and delegate agencies that expend $500,000 or more from Federal awards in a fiscal year, including funds received directly from the Federal Government for other programs, must have a single audit. February 15, 2021: The first mandatory reporting deadline. Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F - this is the guidance that is . Testing requirements for the COVID-19 related funding have not been published but are expected to be addressed in the addendum to . As discussed in that event, for-profits have two options for audit: (1) A financial-related audit in accordance with Government Auditing Standards; or (2) a full single audit (or program-specific audit if eligible). The audit requirements apply to . HHS also has confirmed that for-profit entities that expend $750,000 or more of PRF funds during their fiscal year will be subject to an audit as described in Section 75.216 of HHS' adoption of the Uniform Guidance. A great many nonprofit organizations that received stimulus funding from the federal government during the pandemic are now finding themselves facing unexpected audit requirements. Promptly follow up and take corrective action on audit findings, including preparation of a summary schedule of prior audit findings and a corrective action plan. The Single Audit is a strict and comprehensive financial statement and federal awards audit which must be completed by any entity or organization that expends $750,000 or more in federal funds in one year. 2 STEVEN SHILL. It's official: Single Audits of the Schedule of Expenditures of Federal Awards (SEFA), including Provider Relief Funds (PRF), can proceed. For nonprofits, this may be a significant shock for their 2022 budgets, as a 4.4% budget increase represents a 47% hike compared to the previously standard 3% budget. the Single Audit Act Amendments of 1996; applicable Office of Management and Budget circulars; and other legal, regulatory, and administrative requirements. The Dec. 31, 2021, year end will be the first time the HHS audit requirement takes effect for many for-profit entities. These audits provide assurances to NIH that its grantees have adequate internal controls and comply with certain program requirements.