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HRSA Audits

Our Medical Compliance Experts Help Grant Recipients During and After HRSA Audits

Healthcare providers and commercial organizations that receive grants from the U.S. Health Resources and Services Administration (HRSA) must comply with the HRSA’s auditing policies and procedures. For many grant recipients, this means submitting a Single Audit report to the HRSA each year. But, other requirements may apply as well; and, if the HRSA identifies concerns in a grant recipient’s audit report, the grant recipient may need to participate in the HRSA audit resolution process.

We assist HRSA grant recipients with all aspects of audit compliance. This includes preparing Single Audit reports and other necessary disclosures, safely navigating the HRSA audit resolution process, and managing compliance to ensure a streamlined audit process in the future. With a team that includes a former Assistant Special Agent-in-Charge and Regional Inspector General at the U.S. Department of Health and Human Services Office of Inspector General, we are intimately familiar with in the HRSA’s rules, procedures, and expectations—and we are able to use this familiarity to our clients’ advantage.

Understanding the Audit Process (and Audit Risks) for HRSA Grant Recipients

Under the HRSA’s rules, most grant recipients that expend more than $750,000 have an obligation to submit an annual Single Audit report. Alternatively, “commercial organizations,” including for-profit companies, can submit a financial audit report that complies with the Government Auditing Standards. In either case, compliance is mandatory, and grant recipients must proactively submit their audit reports annually regardless of whether they receive a reminder or prompting from the HRSA.

While smaller grant recipients aren’t required to submit annual audit reports, they must have records available for audit upon request. As a result, all HRSA grant recipients have audit-related obligations, and all recipients must ensure that they have adequate documentation on hand to demonstrate HRSA grant compliance.

Put our highly experienced team on your side

Dr. Stephen Taylor

DOL Consultant

Roger Bach

Former Special Agent (OIG)

Chris Quick

Former Special Agent
(FBI & IRS-CI)

Kevin Smith

Former Assistant Regional Inspector General

Michael Koslow

Former Supervisory Special Agent (DOD-OIG)

James Hunt

Former Special Agent-in-Charge (DEA)

How We Help Organizations During (and After) HRSA Audits

At Fortis, we assist organizations with all aspects of HRSA audit compliance. Compliance is essential, as failing to submit a timely audit report to the HRSA can result in penalties including drawdown restrictions, withholding or suspension of federal funds, reimbursement obligations, and even termination of recipients’ federal grants. If a grant recipient timely submits an audit report and the report suggests non-compliance with the HRSA’s grant requirements, submission can result in federal scrutiny—which can also lead to each of the penalties we just mentioned.

With this in mind, our services for HRSA grant recipients include:

1. Advice and Assistance During HRSA Audits

Grant recipients must satisfy several requirements when preparing Single Audit reports and other audit reports for submission to the HRSA. It is common for grant recipients to work with consultants during this process, and at Fortis we assist our clients with preparing their HRSA audit reports on an annual basis. This way, we get to know our clients well, and we are able to help them implement efficient and effective systems for documenting their expenditures and facilitating streamlined audits. Our HRSA audit consultants assist our clients by:

  • Advising our clients regarding the HRSA’s audit requirements and expectations, including the requirements for Single Audits and Government Auditing Standards-compliant audit reports.
  • Identifying all expenditure records and other documents that need to be reviewed for purposes of the audit.
  • Preparing Single Audit reports and Government Auditing Standards-compliant audit reports for submission to the HRSA.
  • Preparing Corrective Action Plans (CAPs) to include with grant recipients’ audit reports when necessary.
  • Submitting our clients’ audit reports to the HRSA and communicating with HRSA personnel on behalf of our clients to proactively address any potential compliance-related concerns.

When it comes to HRSA grant compliance, a proactive approach is critical. By prioritizing compliance, and by taking the necessary steps to affirmatively demonstrate compliance, grant recipients can avoid scrutiny from the HRSA in most cases. When HRSA personnel have questions, having the documentation on hand to quickly and confidently answer these questions can help to prevent further inquiry.

2. Advice and Assistance During the HRSA Audit Resolution Process

One of the biggest mistakes that we see HRSA grant recipients make is assuming that submitting an annual audit report is nothing more than a formality. This is not the case. The HRSA reviews grant recipients’ audit reports—and, when an audit report omits necessary information or raises red flags for other reasons, the grant recipient must be prepared to clearly explain why.

When a grant recipient cannot explain a deficiency in its audit report, this will typically lead to initiation of the HRSA audit resolution process. This process can present substantial risks for grant recipients that aren’t in compliance, so an informed and strategic approach is critical.

In addition to assisting with preparation and submission of HRSA audit reports, we also provide advice and assistance during the HRSA audit resolution process. Similar to other types of healthcare audits, when handling the HRSA audit resolution process on behalf of grant recipients, our process involves:

  • Conducting an internal compliance and risk assessment to determine whether the HRSA’s inspectors are likely to uncover evidence of overbilling or other grant-related violations.
  • Determining what remedial measures, if any, are necessary to address past grant-related violations and prevent recurrence going forward.
  • Communicating with the HRSA on behalf of our client to proactively address any concerns and begin steering the HRSA’s grant review toward a favorable resolution.
  • Addressing issues as they arise during the audit process, including both procedural miscues and substantive issues involving misapplication of the relevant grant rules and requirements.
  • Facilitating a favorable and final resolution that minimizes the consequences of any past mistakes and establishes a positive working relationship with the HRSA for the future.

Failing to take any of these steps during the HRSA audit resolution process can expose grant recipients to unnecessary penalties—up to and including grant termination. At Fortis, we rely on our experience on both sides of federal healthcare-related enforcement matters to protect our clients to the fullest extent possible.

3. Post-HRSA Audit Compliance Advice and Assistance

Audits can reveal various issues with HRSA grant recipients’ compliance protocols. If an audit identifies issues that your organization needs to address, we can help you address these issues so that they don’t present risks going forward. Along with our audit services, we provide comprehensive compliance services as well, and we can help you move forward with confidence that your organization’s policies, practices, and procedures are not exposing it to potential HRSA scrutiny and grant-related penalties.

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FAQs: What Do Grant Recipients Need to Know About HRSA Audits?

Is the HRSA Going to Review My Organization’s Single Audit Report?

There is a good chance that the HRSA will review your organization’s Single Audit report. The HRSA actively enforces grant recipients’ compliance obligations, and one of the main ways that it identifies compliance failures is by reviewing grant recipients’ audit reports. If your organization’s Single Audit report raises any red flags, this will likely lead to scrutiny from HRSA inspectors.

What Do I Need to Know if the HRSA is Reviewing My Organization’s Audit Report?

If the HRSA is reviewing your organization’s annual audit report, you will want to take a proactive approach to ensuring that the review does not lead to further scrutiny. At Fortis, we work with the HRSA on behalf of grant recipients to assist with resolving audit-related issues before they lead to unnecessary disruptions, costs, and risks.

What Issues Can Come Up During the HRSA Audit Review Process?

Several issues can come up during the HRSA audit review process. Once the HRSA determines that an audit review is necessary, its inspectors will thoroughly examine not only the grant recipient’s documentation supporting the audit report, but also the grant recipient’s grant-related policies and procedures. Issues ranging from inadequate recordkeeping practices to inadequate managerial oversight can lead to grant-related penalties.

What Happens After the HRSA Audit Review Process?

What happens after the HRSA audit review process depends on what happens during the process. At Fortis, we work on behalf of our clients to ensure that the process goes smoothly and does not lead to unnecessary adverse consequences. If the HRSA audit process is resolved unfavorably, this can lead to consequences including drawdown restrictions, reimbursement obligations, suspension, and even grant termination.

Do HRSA Grant Recipients Need to Work With Outside Consultants for Audit Compliance?

Due to the complexity of maintaining HRSA audit compliance and the risks involved with submitting inadequate or inaccurate audit reports to the HRSA, working with a team of experienced outside consultants is strongly recommended. At Fortis, our consultants have extensive experience not only assisting clients with compliance, but also enforcing compliance as former federal law enforcement agents. As a result, we understand both what is at risk and what it takes to avoid unnecessary consequences, and we have a proven record of success helping to protect our clients.

Speak with an HRSA Audit Consultant at Fortis

If you would like to know more about our HRSA audit services for grant recipients, we invite you to get in touch. To speak with a senior HRSA audit consultant at Fortis in confidence, please call 866-808-4160 or request a complimentary consultation online today.

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