Last week we reported that the Health and Human Services (HHS) Provider Relief Fund (PRF) Reporting Portal is open. Recipients of Provider Relief Funds must report on their use of these funds received prior to June 30, 2020 by September 30, 2021. Today, HHS released new guidance for the audit requirements for PRF spending and lost revenue. As a reminder, below is a table describing the deadline for using your Provider Relief Funds (and more information regarding reporting can be found here):
Deadlines for Use of Funds
| Payment Received Period (Payments Exceeding $10,000 in Aggregate Received) | Deadline to Use Funds | |
|---|---|---|
| Period 1 | Payments received April 10, 2020 to June 30, 2020 | June 30, 2021 |
| Period 2 | Payments received July 1, 2020 to December 31, 2020 | December 31, 2021 |
| Period 3 | Payments received January 1, 2021 to June 30, 2021 | June 30, 2022 |
| Period 4 | Payments received July 1, 2021 to December 31, 2021 | December 31, 2022 |
Audit Requirements
The new guidance released today clarifies that entities with fiscal years ending June 30, 2021 will be the first entities required to include Provider Relief Funds on their Schedule of Expenditure of Federal Awards (SEFA) and thus, be subject to audit of these funds. Entities with other fiscal year ends will include some or all of their Provider Relief funds on their next fiscal year end.
For example, if you are a December 31, 2021 year end, then you will include all funds from Periods 1 and 2 (described above) in your SEFA and your December 31, 2022 SEFA will include periods 3 and 4. Below are the specific FAQs that released by HHS.
When should Provider Relief Fund expenditures and/or lost revenue be reported on a nonfederal entity’s Schedule of Expenditures of Federal Awards (SEFA)? (Added 7/15/2021)
Non-federal entities will include Provider Relief Fund expenditures and/or lost revenues on their SEFAs for fiscal year ends (FYEs) ending on or after June 30, 2021. Please refer to the 2021 OMB Compliance Supplement for additional information.
How will a non-federal entity determine the amount of expenditures and/or lost revenues to report on its SEFA for FYEs ending on or after June 30, 2021? (Added 7/15/2021)
A non-federal entity’s SEFA reporting is linked to its report submissions to the Provider Relief Fund Reporting Portal. Therefore, the timing of SEFA reporting of Provider Relief Fund payments will be as follows:
- For a FYE of June 30, 2021, and through FYEs of December 30, 2021, recipients are to report on the SEFA, the total expenditures and/or lost revenues from the Period 1 report submission to the Provider Relief Fund Reporting Portal.
- For a FYE of December 31, 2021, and through FYEs of June 29, 2022, recipients are to report on the SEFA, the total expenditures and/or lost revenues from both the Period 1 and Period 2 report submissions to the PRF reporting porta Provider Relief Fund Reporting Portal l.
- For FYEs on or after June 30, 2022, SEFA reporting guidance related to Period 3 and Period 4 will be provided at a later date.
As discussed in the FAQs above, we will need to wait for the FY2021 OMB Compliance Supplement to be released later this summer for more information.