OFAAM_0906 0083_Below the Audit Threshold Email (New Email)

D elinquent Audit Follow-Up to “Below Threshold” Providers

Subject: Follow Up to Provider Relief Programs Audit Status Update/Attestation

Dear Provider,

Thank you for submitting your attestation/status update regarding the audit of your Provider Relief Fund (PRF), American Rescue Plan (ARP) Rural Distribution, COVID-19 Coverage Assistance Fund (CAF), and Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured (Uninsured Program or UIP) payments that may be required per 45 CFR 75 Subpart F.

In your response, you indicated that you do not believe that you are required to conduct an audit, because you did not expend $750,000 in federal assistance funds during your fiscal year end of [enter applicable fiscal year(s)].  Because determinations regarding audit thresholds and other audit requirements are based on a range of factors specific to each entity receiving federal financial assistance, HRSA is not able to confirm whether you are required to conduct an audit. 

As a reminder, PRF, ARP Rural, UIP and CAF payments are considered federal financial assistance in accordance with the annual Compliance Supplements (2 CFR Part 200, Appendix XI) published by the Office of Management and Budget.

For awareness, entities owning the Tax Identification Numbers (TINs) that received PRF, ARP Rural, UIP and CAF payments are responsible for meeting the audit requirements associated with those payments, even if all or part of the payments were transferred to other entities (e.g., subsidiaries).

If you have not done so already, we recommend that you consult with an accounting professional to determine whether or what type of audit you may be required to conduct.  We note that your determination that you are not required to conduct an audit per 45 CFR 75 Subpart F does not negate the provisions in the Terms and Conditions requiring you to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with the Terms and Conditions associated with your Provider Relief Program (PRP) payments.

Further information about the audit requirements applicable to PRF, ARP Rural, UIP and CAF payments is available at Audit Requirements | HRSA.

Best regards,

PRF Commercial Audit Resolution and Dispute Team

Division of Financial Integrity