[CAFR-Contacts-News] FW: CFDA 93.461 COVID-19 Testing for the Uninsured

Thu Feb 11 10:16:28 PST 2021

Hello CAFR Contacts,

It does not appear that we have any expenditures yet under CFDA 93.461, as it's not on the D40 profile in SFMA, but in case there are some to come in FY 2021, the information below may be of value for your agencies, especially those involved with hospitals and health departments.

Rob

From: Poynter, R. Kinney <kpoynter at nasact.org>
Sent: Thursday, February 11, 2021 9:56 AM
To: NSAAAuditors <NSAAAuditors at nasact.org>; NASCComptrollers <NASCComptrollers at nasact.org>; StateTreasurers <StateTreasurers at nasact.org>; NSAA2021SingleAuditCommittee <NSAA2021SingleAuditCommittee at nasact.org>; NASCCAFR <NASCCAFR at nasact.org>; UniformGuidanceImplementationWorkgroup <UniformGuidanceImplementatinWorkgroup at nasact.org>
Cc: NSAAAuditorsCCs <NSAAAuditorsCCs at nasact.org>; NASCComptrollersCCs <NASCComptrollersCCs at nasact.org>; StateTreasurersCCs <StateTreasurersCCs at nasact.org>; Rowland, Sherri <srowland at nasact.org>; Chebinou, Cornelia <cchebinou at nasact.org>; Strudgeon, George <george.strudgeon at apa.virginia.gov>
Subject: CFDA 93.461 COVID-19 Testing for the Uninsured
Importance: High

NASACT Members -

George Strudgeon, Audit Director - Compliance Assurance, Virginia Auditor of Public Accounts, brought the following issue relating to CFDA 93.461 (COVID-19 Testing for the Uninsured) to our attention. This could potentially impact both auditees and auditors, specifically those that have medical providers (e.g. university and state hospitals, health departments, etc.) included within the financial statements they compile or audit, respectively.

Many thanks to George for bringing this issue to our attention.

Thank you,

R. Kinney Poynter, CPA
NASACT Executive Director
(859) 276-1147

Background:
CFDA 93.461 which goes by the name "COVID-19 Testing for the Uninsured" within the 2020 Compliance Supplement Addendum<https://www.aicpa.org/content/dam/aicpa/interestareas/governmentalauditquality/resources/singleaudit/uniformguidanceforfederalrewards/downloadabledocuments/2020-omb-comp-supp/hhs-2020-compliance-supplement-addendum-final.pdf> but now beta.sam.gov is reporting its name as "COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured."  The change in name is not the issue; however, it does appear to indicate that the scope of this program has expanded and will have a bigger impact for 2021.  As for 2020, here is the issue along with a request for information that could help your membership.

Issue:
Federal documents describe the program as if it operates as a claims reimbursement program similar to Medicaid and Medicare.  As a result, some medical providers may have not reported the funding for CFDA 93.461 within the SEFA similar to how they do not report funding for Medicaid and Medicare related to claims.  See Example 1 Guidance below for an example of guidance that may cause a provider to believe that, same as Medicaid and Medicare claim reimbursement, that this program may not be reported on the SEFA.  However, as seen in Example 2 Guidance below, HRSA states that CFDA 93.461 must be included in the Single Audit.  The Example 2 Guidance is consistent with information currently at beta.sam.gov for this program<https://beta.sam.gov/fal/f042fd7ea46a49709f7e52618a2fd339/view?keywords=93.461&sort=-relevance&index=&is_active=true&page=1>.

What would be Helpful to the States:
We did some searching of the internet to determine if HRSA has publicly reported its payees for entities that received funding under CFDA 93.461; however, we were unable to locate this type of listing.  We believe that this type of listing would be helpful for us an other states to ensure SEFAs are complete.  I have copied Tammie on this email because she is aware of this issue and may know of a listing that discloses the entities that received funding under CFDA 93.461 for state fiscal year 2020 and/or other guidance that may help the states.

Example 1 Guidance:
[cid:image005.jpg at 01D70075.387FEB40]
Source: https://www.hrsa.gov/coviduninsuredclaim/frequently-asked-questions

Example 2 Guidance:
[cid:image006.jpg at 01D70075.387FEB40]

Source: https://www.hhs.gov/sites/default/files/provider-relief-fund-general-distribution-faqs.pdf

George D. Strudgeon, CPA, CGMA, CGFM, MBA
Audit Director - Compliance Assurance
804-362-7804 (direct) (new as of 8/3/2020)
804-225-3350 (office main line)
George.Strudgeon at apa.virginia.gov<mailto:George.Strudgeon at apa.virginia.gov>
www.apa.virginia.gov<http://www.apa.virginia.gov/>

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://omls.oregon.gov/pipermail/cafr-contacts-news/attachments/20210211/e9919b0e/attachment-0001.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image003.jpg
Type: image/jpeg
Size: 20605 bytes
Desc: image003.jpg
URL: <https://omls.oregon.gov/pipermail/cafr-contacts-news/attachments/20210211/e9919b0e/attachment-0002.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image004.jpg
Type: image/jpeg
Size: 26765 bytes
Desc: image004.jpg
URL: <https://omls.oregon.gov/pipermail/cafr-contacts-news/attachments/20210211/e9919b0e/attachment-0003.jpg>