Single Audit Updates

Thoughtware Alert Jul 27, 2020
Healthcare COVID-19

Provider Relief Funds – CFDA 93.498

After much deliberation, the U.S. Department of Health & Human Services (HHS) has provided a definitive answer regarding the Single Audit requirements for nonfederal and for-profit entities expending funds under the new Provider Relief Fund (PRF) program created as part of the Coronavirus Aid, Relief, and Economic Security Act. HHS has confirmed these funds will be subject to Single Audit for nonfederal entities that expend $750,000 or more of these funds during their fiscal year. Many nonfederal entities are expected to be subject to Single Audit requirements for the first time as a result of this requirement. 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. That section describes two options available for audits of commercial organizations:

  1. A financial-related audit of a particular award or multiple HHS awards in accordance with Government Auditing Standards
  2. A full Single Audit that meets the requirements contained in Subpart F of the Uniform Guidance. More information on best practices for for-profit engagements is expected in the coming weeks

U.S. Small Business Administration Paycheck Protection Program – CFDA 59.073

As a reminder, some organizations may have received loans under the Paycheck Protection Program (PPP). However, PPP funding isn’t subject to the Uniform Guidance or Single Audit rules.

Federal Communications Commission COVID-19 Telehealth Program – CFDA 32.006

There has been a change in position by the Federal Communications Commission whereby Uniform Guidance subparts B, E, and F apply to the COVID-19 Telehealth Program (CFDA 32.006). Previously, beta.sam.gov indicated the program wasn’t subject to Uniform Guidance, which was an error that has recently been corrected. As a result of Subpart F of Uniform Guidance applying to this program, the program is subject to Single Audit requirements.

Compliance Supplement

The Office of Management and Budget has indicated the 2020 supplement will likely be issued in two parts this year. The first part will focus primarily on what was developed prior to the COVID-19 pandemic, but it’s also expected to include some limited information related to the COVID-19 pandemic, including a summary of new COVID-19 programs.

The second part of the supplement will be an addendum addressing new COVID-19 programs referenced above (as well as many others, such as Coronavirus Relief Fund (CFDA 21.019) and Education Stabilization Fund (CFDA 84.425)) in more detail and is expected this fall.

Other Helpful Links & Resources

  1. Coronavirus Relief Fund Frequently Asked Questions (FAQ) (last updated as of July 8, 2020)
  2. Coronavirus Relief Fund Guidance for State, Territorial, Local, and Tribal Governments (updated June 30, 2020)
  3. Department of the Treasury Memo for Coronavirus Relief Fund Recipients
  4. BKD Webinar Archive – COVID-19 Funding Compliance: Preparing for Your First Single Audit
  5. Governmental Audit Quality Center (GAQC) Alert No. 411
  6. GAQC Summary of Uniform Guidance Applicability for New COVID-19-Related Federal Programs
  7. HHS Provider Relief Fund FAQs
  8. GAQC Alert No. 404

Please note that this information is current as of the date of publication, as legislation and guidance are constantly evolving. Reach out to your BKD Trusted Advisor™, submit the Contact Us form below, or visit our COVID-19 Resource Center for current information.

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