Providers who received over $750,000 PRF are also subject to a compliance audit. Commercial organizations have two options in fulfilling the audit requirement: 1) an audit in conformance with the requirements of 45 CFR 75 Subpart F (single audit), or 2) a financial audit of the award or awards in accordance with 政府审计准则.
Amounts reported on the schedule in the PRF audit (regardless of the option chosen as described above) will align with the PRF period of availability 和 what is reported in the PRF Reporting Portal. 日历年结束时, total expenditures 和 lost revenues from both 期 1 和 期 2 report submissions to the Health Resources 和 Services 政府 (“HRSA”) PRF reporting portal would have been included on the 12/31/21 schedule in the PRF audit. This would include PRF funding received from April 10, 2020, to December 31, 2020. 审计s for calendar year-ends of December 31, 2022 will include 期 3 和 期 4 payments.
除了PRF数额之外, the schedule should also include any other HHS awards received during 2021 including 93.461, COVID 19 Claims Reimbursement for the Uninsured Program 和 the COVID-19 Coverage Assistance Funds (Assistance Listing 93.461), COVID-19 Testing 和 Mitigation for Rural Health Clinics (assistance listing 93.697), 和 other HHS awards such as NIH Research 和 Development grants.
The compliance audits are due the earlier of 30 days after the receipt of the audit or nine months after fiscal year end.
The Office of Management 和 Budget (“OMB”) granted a six-month extension for recipients in Puerto Rico, 阿拉斯加, 佛罗里达, 南卡罗来纳, 和 North Carolina with Single 审计s due between September 18 和 December 31, 2022.
Many organizations have been through their first compliance audit for the HHS awards. Below are some common compliance audit issues identified in these audits:
- Missing or incorrect information – 审计ors are required to agree certain line items of the HRSA PRF portal submission to the underlying detail. 在某些情况下, providers were unable to provide supporting detail, or the supporting detail provided did not agree to what was reported in the submission.
- Expense reporting – Expenses reported in the HRSA PRF portal submission as “Other PRF Expenses” should only include the PRF expenses for that reporting period. 这些不应该是累积的.
- Alternative Reasonable Methodology narrative – The narrative included for the lost revenue calculation did not support the calculation or did not include an explanation of why the methodology was reasonable for the circumstances 和 how the lost revenues were attributable to COVID.
As providers prepare for the next round of compliance audits, below is information to keep in mind:
- Ensure all HHS award information is readily available 和 supports amounts reported in the HRSA PRF portal.
- Ensure policies 和 procedures surrounding the funding are documented 和 accurately depict the use of the funds 和 the controls in place over the funds.
- Review the related compliance requirements. The OMB releases a compliance supplement which details the compliance requirements for the funds. Providers should review these to gain a better underst和ing of the testing to be performed as part of the compliance audit.