We recently communicated that the Provider Relief Fund Reporting Portal is Now Open, which raised additional questions regarding inclusion of the funds on the Schedule of Expenditure of Federal Awards (SEFA). As discussed in the communication, the reporting of the funds to the U.S. Department of Health and Human Services (HHS) was altered to correspond with the timing of when the payments were received from HHS, regardless of the timing of expenditures and/or lost revenues. Reporting is a significant component of compliance for audit purposes. Since HHS has tied reporting to inclusion, changes were made as to when the funds should be included on the SEFA and recently communicated in a FAQ issued by HHS on July 15, 2021.
- 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 PRF 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 Portal.
- 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.
With the changes noted above, PRF amounts should be excluded from the SEFA through FYE’s June 29, 2021 and begin to report on FYE June 30, 2021. This guidance does supersede the guidance provided in the 2020 OMB Compliance Supplement Addendum, which stated that PRF would begin to be reported on SEFAs for December 31, 2020, and later FYEs.
As of now, for profit entities are to follow the same guidance; however, the AICPA Government Audit Quality Center anticipates that there could be further guidance for these entities. Since the information above does supersede the 2020 OMB Compliance Supplement Addendum, updates regarding PRF compliance and auditing will be included in the 2021 OMB Compliance Supplement. The 2021 Supplement should be released soon.
Understanding the complexities of reporting and subsequent inclusion on the SEFA can be difficult to navigate. For any questions related to this Provider Relief Fund update, please contact Stephanie Allgeyer at sallgeyer@vlcpa.com or 800.887.0437.
