I Received an HRSA “Audit Reporting Requirement Attestation” Email. Now what?

At a glance:

• What was sent: If you received an email from HRSA saying that you must provide a single audit related to funds you received through the CARES Act and /or American Rescue Plan, your reporting deadline is April 5, 2024, and you must respond.
• Who is impacted: Healthcare providers, physician practices, and others may have received funds from the Provider Relief Fund (PRF) or American Rescue Plan Rural Distribution Funds (ARP Rural) as part of the HRSA COVID-19 Uninsured Program and the Coverage Assistance Fund. Recipients were subject to reporting terms and conditions, which included submitting single audit reports showing the funds were expended in compliance with the program requirements.
• Next steps: If you spent $750,000 or more in a single fiscal year and haven’t submitted your audit report to HRSA, and you received notice from the HRSA, you must submit your audit report or email a signed engagement letter to PRFaudit@hrsa.gov showing that you are working with an independent certified public accountant to conduct an audit of how you expended those funds. If you do not take this action by April 5, 2024, your account could be sent to the U.S. Department of Treasury’s Centralized Receivables Service for collection.

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The full story:

While the COVID-19 pandemic may feel like a distant memory, some physicians practices and healthcare providers who received Audit Reporting Requirement Attestations emails from the Health Resources and Services Administration (HRSA) recently may feel otherwise.

If you received an email from the HRSA saying that you must show the funds received as part of the Provider Relief Fund (PRF) or American Rescue Plan Rural Distribution Funds (ARP Rural) were expended in compliance with the program requirements, you must respond by April 5, 2024. Here’s what to do about it.

Who’s impacted by the latest HRSA reporting requirements?

If you received and spent more than $750,000 in a single fiscal year and do not comply with new deadlines issued by the HRSA, you could potentially be in violation of terms and conditions related to required audit reporting.

The Provider Relief Fund terms and conditions are outlined in the Uniform Guidance Audit requirements, in the regulations at 45 Code of Federal Regulations (CFR) § 75 Subpart F.

That requirement applies to both nonprofit and for profit healthcare providers who received PRF payments or were reimbursed for services by the HRSA COVID-19 Uninsured Program and the Coverage Assistance Fund. Recipients were required to submit reporting to the HRSA Provider Relief Bureau on how you used those funds.

The most recent notices emailed by HRSA related to the Audit Reporting Requirements apply largely to providers who have not yet submitted the required attestation reporting.

What if I spent $750,000 or more in a single fiscal year and haven’t submitted my report to the HRSA?

This is the most urgent scenario and requires immediate attention.

If you haven’t submitted your report to HRSA (the most recent reporting period closed on March 31, 2024) AND you have not engaged an independent certified public accountant (CPA) to conduct an audit, it is imperative that you engage a CPA immediately to prepare an engagement letter to demonstrate that you have engaged an independent auditor to perform the required audit.

You must then submit that audit engagement letter to the PRB at: PRFaudits@hrsa.gov no later than Friday, April 5, 2024.

What if I have a single audit but haven’t submitted it?

If you spent $750,000 or more in funds you received from the aforementioned sources and engaged an independent CPA for a single audit of how you expended those funds, you must submit that audit to HRSA by following the instructions in the HRSA Audit Reporting Requirement Attestation Notice you received.

What if I spent less than $750,000 in each fiscal year and still received an HRSA notice?

If you spent less than $750,000 in the aforementioned funds in a single fiscal year, AND you submitted PRF reports showing that, and are certain those reports and accounting are correct, you may email the HRSA and notify them that they sent the Audit Reporting Requirement Attestation in error.

What if I received a final repayment notice from the HRSA?

You may have received a final repayment notice from HRSA. If you disagree with its assessment, you may submit a request to have the HRSA reconsider its decision. The portal allows providers to tell their story about how they spent the funds they received.

You can file this request at the HRSA Decision Portal. Note that you must respond to this letter from HRSA requesting repayment of funds within 60 calendar days of the date of the letter.

The HRSA has also provided a detailed guide on how to use the Decision Portal that you may reference before submitting your request.

The bottom line

If you received any correspondence from HRSA saying that you must provide a single audit related to funds you received under the Provider Relief Fund or American Rescue Plan Rural Distribution Fund, you need to respond immediately. If you do not submit a final audit report or an executed engagement letter by the April 5 deadline, you could have your account sent to the Program Support Center’s Debt Collection Center, and no one wants that.

If you need immediate assistance with an engagement letter for a single audit report, reach out to Aprio now. Even if it is determined that you do not need an audit, the engagement can be terminated.

The worst thing you can do is not respond by the deadline. Submitting a signed engagement letter gives you time to file your response with the HRSA and straighten your situation out.

Related Resources

6 Healthcare Insights from Q4 2023 and What They Mean for You: https://www.aprio.com/6-healthcare-insights-from-q4-2023-and-what-they-mean-for-you/

Mark Armstrong Joins Aprio to Lead National Healthcare Practice:
https://www.aprio.com/mark-armstrong-joins-aprio-to-lead-national-healthcare-practice/

Healthcare CPA and Advisory Services: https://www.aprio.com/industries/healthcare-services/

If you received an email from the HRSA saying that you must provide a single audit related to funds you received under the Provider Relief Fund (PRF) or American Rescue Plan Rural Distribution Funds (ARP), connect with Aprio Assurance Partner, Rob Shirley, today.