Provider Relief Funds – OMB Compliance Supplement Addendum

Provider Relief Funds – OMB Compliance Supplement Addendum

by Liz Marek, Grace Williams
March 04, 2021

If your organization received provider relief funds from the Department of Health and Human Services (HHS) you may be subject to the Office of Management and Budget’s (OMB) single audit requirement.

On December 22, 2020, the OMB issued its 2020 Compliance Supplement Addendum providing guidance on auditing coronavirus aid, relief, CARES Act money and other COVID-19 relief programs.

Effective Date and Access Information

  • The effective date of the supplement addendum is the same as the original 2020 OMB Compliance Supplement (the August 2020 Supplement) for audits of fiscal years beginning after June 30, 2019. The addendum must be used in conjunction with the August 2020 Supplement in determining the appropriate audit procedures to support the compliance opinion.

Audit Submission Extension

  • Awarding agencies must allow recipients and subrecipients that received COVID-19 funding with original due dates from October 1, 2020, through June 30, 2021, an extension of up to three months beyond the normal due date for the completion and submission of the single audit reporting package.

Schedule of Federal Expenditures (SEFA) and Provider Relief Funds (PRF)

  • The other information section in the PRF section of the supplement addendum instructs that PRF expenditures and lost revenue will not be included on SEFAs until December 31, 2020, year-ends and later.
  • An entity with a fiscal year ending December 31, 2020, will report PRF expenditures (including lost revenues) on the SEFA based upon the December 31, 2020 PRF report to be filed with HHS. The HHS has indicated that the PRF reporting portal is not currently available for the submission of reporting data. The department will notify recipients of the reporting timeline. The footnotes to the SEFA must disclose that the PRF amount included on the SEFA is based upon the December 31, 2020 PRF report.
  • Entities with fiscal years ending in 2021 prior to June 30, 2021, will report PRF expenditures (including lost revenues) on the SEFA based upon the PRF report for the calendar year ending December 31, 2020, and disclose in the footnotes to the SEFA that the amount included on the SEFA is based upon the December 31, 2020, PRF report.
  • SEFA reporting guidance for fiscal years ending on or after June 30, 2021, will be addressed in the 2021 compliance supplement.
  • Entities with fiscal years ending in 2020 on or before December 30, 2020, will report no PRF expenditures (including lost revenues) on the SEFA. Entities will report 2020 PRF expenditures (including lost revenue) in their 2021 single audit.

What does this mean for your Organization?

  • Many healthcare entities are faced with a single audit requirement for the first time.
  • Both non-profit and for-profit healthcare entities that incurred expenditures (including lost revenues) of PRF funds of $750,000 or more are subject to the single audit requirement.
  • Entities requiring the single audit will be subject to new compliance and reporting requirements.

If you have any questions about the provider relief funds, OMB single audit or want to learn how Armanino can assist you through the process, don’t hesitate to contact our dedicated Healthcare Audit team for help.

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Liz Marek - Senior Manager, Audit - San Ramon CA | Armanino
Senior Manager
Grace Williams - Audit | Armanino
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