Provider Relief Funds: Commercial Organizations May Require External Audit

Current U.S. Department of Health and Human Services (HHS) regulations could impose an external audit requirement on commercial recipients of provider relief funds (PRF) under the CARES Act. If affected, the organization would need to contract with a CPA firm to perform the required audit.

What are the Source Regulations?

45 Code of Federal Regulations (CFR) 75.216 and 501(i) and (j) states that “Commercial Organizations” who receive HHS awards of $750,000 or more in a fiscal year are required to have either of the following two external audits performed within nine months of year end:

  1. A Single or program-specific audit (Single Audit) in accordance with 45 CFR Part 75 – Subpart F;

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Provider Relief Funds: Reporting – Key Matters and Requirements as Guidance Continues to Evolve

Recipients of Provider Relief Funds (PRF) under the CARES Act have spent 2020 and the beginning of 2021 navigating the evolving guidance related to this program. There have been many questions related to PRF and, ultimately, the reporting that will be required.

On Friday, January 15, 2021, the Provider Relief Fund Reporting Portal opened for registration and PRF recipients are now getting closer to final guidance on what will be necessary to include in the December 31, 2020 report that is due in early February. Given the guidance we now have available, this article will give a brief overview of the report and its requirements.

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