By: Cindy Pratt
Recently, Community Health Centers (CHC), along with other HRSA recipients that spend $750,000 or more in Federal awards during their fiscal year, received a notice about late reporting of the required Single Audit. This notice emphasized the need for CHCs to submit Single Audits within the required timeframe or face potential action applied to their HRSA grant(s) for non-compliance.
The requirement to complete an annual Single Audit is not new. It is detailed in 45 CFR Part 75, Subpart F, found here: https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-A/part-75/subpart-F. The audit must be submitted electronically to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period.
The email sent out on April 2, 2024, stated that effective April 2024, recipients that have not provided their Single Audits by the deadline will receive a letter from HRSA with specific timeframes to submit their delinquent audit report(s) and additional action that could be taken by HRSA with continued delays. Failure to submit on time is considered non-compliance with the terms and conditions of the Federal award and 45 CFR 75.371 details actions that HRSA can take, including: requiring CHCs to provide documentation of eligible expenses before approving funds in the Payment Management System (PMS); temporarily withholding cash payments pending correction of the deficiency; withholding further federal awards for the project; or terminating the Federal award.
Obviously, none of us want to be in a position where we are delinquent in our Single Audit submission. Over the past few years, many CHCs have unfortunately found themselves in this position due to delays in the ability of our audit partners to complete audit processes in the same timeframes as they did prior to COVID. The primary factor causing the delays is the significant staffing crisis that has plagued the finance and accounting industry since COVID, resulting in turnover and short staffing in both CHCs and our audit partners.
If your CHC has found itself out of compliance with a delinquent Single Audit, communication is key to navigating a resolution. Communication with both your audit partner and HRSA should be transparent and frequent to ensure that all parties are aware of the situation, expectations are clear, and specific milestone deadlines are established within a reasonable timeframe to achieve the desired outcome. Respectfully engaging your audit partner through regular check-ins is crucial to moving the project along as expected and quickly identifying any barriers so solutions can be discussed and implemented.
Need Support?
At CLC, we're dedicated to being your reliable support system. Whether you require assistance with audit preparation, project management, a friendly voice for guidance, or reviewing your data, we're thrilled to help at every step.
Our expertise shines in specific areas such as compiling reconciliations and supporting schedules, patient revenue allowance for doubtful accounts, fixed asset depreciation schedules, or reviews of audit documentation. We're here to make these processes smoother and more manageable for you! Contact us for help at info@communitylinkconsulting.com