Emergency Clearance Memo

5600 Fishers Lane
Rockville, MD 20857

DATE

February 1, 2024

TO:

Richard Revesz, Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget

FROM:

Diana Espinosa, Principal Deputy Administrator

SUBJECT:

DECISION - Request for Emergency Approval – COVID–19 Provider Relief
Programs Single and Commercial Audits and Delinquent Audit Reporting
Submission Activities

ACTION REQUESTED
The Health Resources & Services Administration (HRSA) is requesting Paperwork Reduction
Act (PRA) emergency approval (as detailed under 5 C.F.R § 1320.13) for Provider Relief
Programs (PRP) single and commercial audits and delinquent audit reporting submission
activities. HRSA needs emergency approval for this information collection request (ICR)
because HRSA cannot reasonably comply with the normal PRA clearance procedures without
disrupting the collection of mission-critical information and limiting HRSA’s ability to conduct
required oversight of the federal program. HRSA requests that the Office of Management and
Budget approve this emergency ICR within 7 calendar days of receipt of this memo.
DISCUSSION
HRSA administered the PRP and issued payments to health care providers for expenses or lost
revenue attributable to the COVID-19 and claims reimbursement for COVID-19 testing,
treatment and vaccine administration for uninsured and underinsured individuals. The non-profit
providers who received funding are subject to the Single Audit Act and HRSA applied a parallel
requirement to commercial organizations who are not subject to the Single Audit Act. In late
calendar year 2023, HRSA learned that the Department of Health and Human Services would not
be able to support the delinquent audit process for commercial organizations (as the Department
does for non-profit organizations) and that HRSA would need to develop its own delinquent
audit process. During this time, HRSA learned that the commercial audits and associated
activities are subject to the PRA and are not covered under the Federal Audit Clearinghouse ICR.
Some commercial providers have already submitted their audits. HRSA will use the collected
information to help ensure all providers who expended over $750,000 in funding from any PRP
submit: (1) an audit, (2) documentation and attestation needed to resolve audit findings, or (3) an
attestation or documentation to demonstrate an audit is not required. HRSA needs this
emergency approval since waiting 6-9 months would further delay communicating with
providers about audit reports and recovering federal funds not used in accordance with the PRP
Terms and Conditions and 45 CFR 75.
Health Resources and Services Administration
www.hrsa.gov

Administrator
Office of Information and Regulatory Affairs
Page 2

HRSA is submitting this ICR to the Office of Management and Budget for a 6-month emergency
approval and appreciates your assistance with our program oversight and program integrity
efforts. Once this clearance is granted, HRSA will create a regular ICR for this collection.
Diana Espinosa

__________________________

Health Resources and Services Administration
www.hrsa.gov