PYA Covid-19 Information Hub
Published July 20, 2021

The Wait Is Over, for Now: HHS Provides Guidance on SEFA Reporting

On Thursday, July 15, 2021, the Department of Health and Human Services (HHS) released updated auditing and reporting requirements to the Provider Relief Funds (PRF) Frequently Asked Questions (FAQs). The good news: many single audits of non-federal entities can now be finalized, as PRF may be outside the scope of the single audit depending on the recipient’s fiscal year-end (FYE). The bad news: HHS continues to omit guidance on for-profit recipients of PRF funding, and the 2020 Compliance Supplement still lacks guidance for auditing PRF. There are two key takeaways from the updated FAQs:

  1. Non-federal entities will only need to include PRF expenditures and/or lost revenues on their Schedule of Expenditures of Federal Awards (SEFA) for FYEs on or after June 30, 2021. This means PRF will be excluded from the SEFA and the scope of single audit requirements for non-federal entities for FYEs ending on December 31, 2020, through June 29, 2021.
  2. The amount of the expenditures and/or lost revenues reported on the SEFA are determined using the reporting time periods established by HHS on Friday, June 11, 2021, as discussed in a previous PYA Insight and illustrated below:

Period

Payment Received Period
(Payments Exceeding $10,000 in Aggregate Received)

Deadline to Use Funds

Reporting Time Period

Period 1

April 10, 2020 to June 30, 2020

June 30, 2021

July 1, 2021 to September 30, 2021

Period 2

July 1, 2020 to December 31, 2020

December 31, 2021

January 1, 2022 to March 31, 2022

Period 3

January 1, 2021 to June 30, 2021

June 30, 2022

July 1, 2022 to September 30, 2022

Period 4

July 1, 2021 to December 31, 2021

December 31, 2022

January 1, 2023 to March 31, 2023

Using the reporting time periods previously illustrated, the reporting of expenditures and/or lost revenues 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 (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 Reporting Portal.
  • For FYEs on or after June 30, 2022, SEFA reporting guidance related to Period 3 and Period 4 will be provided later.

In addition to these reporting updates, HHS clarified how to return unused PRF monies in the Reporting Portal. See PYA’s step-by-step guide on the PRF reporting process.

During our Provider Relief Fund Reporting Requirements webinar on July 21, 2021, members of PYA’s PRF Task Force took a deeper dive into some of the more challenging aspects of the reporting process.

To learn how PYA can assist your organization with PRF compliance and reporting, contact a PYA executive below at (800) 270-9629.

Executive Contacts

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