The United States Department of Health and Human Services (HHS), Office of Inspector General (OIG) recently posted a new educational resource on its website about Single Audits. HHS is the largest grant-making agency in the Federal government, and OIG’s new resource is designed to help key stakeholders understand the scope of Single Audits, as well as improve the overall quality of such audits.[1]
The Single Audit Act requires non-Federal entities that expend $750,000 or more in Federal Financial Assistance (e.g., grants, cooperative agreements, direct payments for specified use awards, and loans) in a fiscal year to undergo a Single Audit conducted by an independent external auditor. Health care providers expected to need Single Audits include, but are not limited to, Federally Qualified Health Centers (FQHCs), academic medical centers, hospitals, research institutes, and those receiving Provider Relief Funds. Single Audits are principally comprised of a review of: (1) financial statements, including policies, supplemental documentation such as the Schedule of Expenditures of Federal Awards, and internal controls; and (2) the entity’s compliance with the requirements of their Federal awards, including an examination of award spending and performance progress.
Any findings identified during the Single Audit typically include the criteria, condition, cause, effect or potential effect, questioned or likely questioned cost, views of the responsible officials, and recommendations. Entities are required to develop a corrective action plan to address the root cause for reported findings. Such entities also must submit their completed Single Audit reporting package to the Federal Audit Clearinghouse within 30 days after receipt of the Single Audit Report or nine months after the end of the audit period, whichever occurs first.
OIG uses Single Audits to identify instances of mismanagement of Federal funds, non-compliance, or indications of fraud, waste, and abuse. In particular, OIG conducts desk reviews, performs quality control reviews, and provides technical assistance to ensure that taxpayer dollars are being safeguarded and spent for their intended purposes.
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and subsequent legislation, authorized billions of dollars of COVID relief funding for health care providers. Providers (including organizations) that received and spent more than $750,000 in Provider Relief Funds are subject to the Single Audit Act and must retain an independent auditor to perform a Single Audit. Consequently, providers who may have never needed to conduct a Single Audit before are now required to do so pursuant to the terms and conditions associated with those grants. Additionally, OIG’s oversight of CARES Act programs is increasing, so the new OIG resource will help guide providers through the Single Audit process.
Garfunkel Wild is uniquely situated to help providers with Single Audits. Should you require assistance or would like more information, please contact the Garfunkel Wild attorney with whom you regularly work, or contact us at [email protected].
A copy of OIG’s new resource on Single Audits is available at: https://oig.hhs.gov/compliance/single-audits/