Healthcare entities that received federal funding related to COVID-19 relief programs may now be subject to single audit requirements under the Office of Management and Budget (OMB) memorandums including Provider Relief Fund, the Coronavirus Relief Fund, and other HHS programs. More guidance from the OMB is expected to follow on some of these programs.
Non-profit and governmental entities
Non-profit and governmental entities (i.e., states, local governments, and nonprofits) will be subject to single audit requirements if the entity has annual total federal awards expended of $750,000 or more.
For-profit entities
The Health and Human Services (HHS) has provided guidance that for-profit entities (medical practices, hospitals, skilled nursing facilities, ASCs, etc.) will also be subject to single audit requirements if the entity received annual total awards of $750,000 or more in federal funds.
For-profit entities can meet this audit requirement by obtaining a financial audit of an award or multiple HHS programs in accordance with Government Auditing Standards or a full single audit that meets the requirements contained in Subpart F of the Uniform Guidance.
Filing deadlines for the audits are as follows:
| Entity year end | Due date |
| June 30, 2019 – September 30, 2019 | 15 months from year end |
| October 31, 2019 – December 31, 2019 | 12 months from year end |
| January 31, 2020 – December 31, 2020 | 9 months from year end |
If you have questions about how this new guidance could affect your healthcare organization, reach out to a member of our healthcare team.
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