Implications of a Delinquent HRSA Data Collection Form
Every year, an entity who receives Health Resources and Services Administration (HRSA) funding and is required to have a single audit performed must submit their Data Collection form (DCF) to the Federal Audit Clearinghouse (FAC) either 9 months after their fiscal year end or 30 days after the single audit financial statements have been final issued, whichever is earlier.
The Data Collection form includes the final financial statements, Schedule of Expenditures of Federal Awards, Auditor’s Report, Summary Schedule of Prior Audit Findings, Schedule of Findings and Questioned Costs, and, if applicable, the Correct Action Plan.
Delinquent Implications from HRSA
If one’s DCF is delinquent, HRSA will follow up to ensure that the delinquent status is resolved. The first notification will include a request to submit the required reports and to provide an estimated submission date of the required reports to HRSA. HRSA typically allows up to a 14-day window for the organization to submit the required response. If no communication is received, HRSA will attempt two more times. After the third attempt, HRSA may take the following actions: 1) Change the drawdown status to either ‘reimbursable drawdown’ or ‘temporary freeze’ within the Payment Management System (PMS); 2) Withhold a percentage of federal funds; 3) Suspend federal funds; and/or 4) Terminate the grant.
The organization will also appear on a delinquent single audit status report every quarter until resolved, which gets submitted to the Department of Human Health Services (DHHS).
Therefore, in order to not jeopardize one’s HRSA funding, it is crucial that 1) The organization timely submits their HRSA DCF; or 2) If one is delayed, they timely respond to the HRSA delinquent notifications. A helpful tip, if one is aware that their organization will not timely submit the DCF, it is best practice to let HRSA know in advance.
Delinquent Implications on the Single Audit
A delinquent single audit submission would be considered noncompliance with federal regulations and the terms and conditions of federal awards. Therefore, this would be considered a noncompliance finding and would be reported as such in the Schedule of Findings and Questioned Costs of the single audit report.
Given that this is a finding that is reported in the single audit report, a corrective action plan would be required to be submitted.
In future audits, this would also change one’s status to no longer being a low-risk auditee. Being classified as a high-risk auditee means that the auditors will need to test a larger percentage of the federal awards to ensure compliance. This means that more work will be performed by the auditors, which will require additional support to be provided by the organization.
Therefore, in order to not jeopardize one’s low-risk auditee status, 1) Ensure that an audit timeline is in place that will meet the DCF deadline; 2) Communicate timely with the auditors of any new updates in information that is different from the previous years to eliminate any unnecessary delays; and 3) Ensure that all proper documentation has been maintained throughout the year, so the organization is prepared for single audit fieldwork.
If you have questions about the information outlined above, McKonly & Asbury’s experienced professionals are here to help. Learn more about our Healthcare practice by visiting our Healthcare industry page or by contacting the Director of our Healthcare practice, Janice Snyder, Partner.
About the Author
Kady joined McKonly & Asbury in 2016 and is currently a Manager with the firm. As a member of the Audit & Assurance Segment, she focuses on providing client services, particularly in the areas of healthcare entity audits and single… Read more
