HRSA Audits

Our Consultants Advise Healthcare Entities Before, During, and After HRSA Audits

HRSA Audit Team Lead – Timothy E. Allen | Former Special Agent (U.S. Secret Service & DOJ-OIG)

The U.S. Health Resources & Services Administration (HRSA) audits healthcare providers and other organizations for compliance with the terms of their federal grants. Under the HRSA’s regulations, most grant recipients must submit audit reports annually, and these audit reports are subject to review by the HRSA’s internal personnel. When a grant recipient’s audit report exposes billing violations or raises red flags for fraud, this can trigger scrutiny from the HRSA—and potentially from other federal authorities as well.

As a result, grant recipients must take the HRSA audit process very seriously. They must work with experienced consultants to ensure that their audit reports meet all regulatory requirements, and they must also work with their consultants to proactively address any areas of concern. In the event that the HRSA initiates its audit resolution process or initiates its own audit or investigation, grant recipients must rely on their consultants (and potentially outside counsel) to help them avoid unnecessary consequences.

Experienced Healthcare Fraud Defense Consultants for HRSA Audits Nationwide

We assist healthcare providers and other organizations with HRSA audits nationwide. Our consultants assist organizations throughout the process—from ensuring that their audit reports will withstand HRSA scrutiny to assisting with defense against HRSA (and other agency) audits and investigations. With deep experience in the federal healthcare arena, including prior experience as healthcare fraud investigators, our consultants are well-versed in all areas of HRSA auditing and grant compliance.

Put our highly experienced team on your side

Roger Bach

Former Special Agent (OIG)

Timothy E. Allen

Former Senior Special Agent U.S. Secret Service

Chris J. Quick

Former Special Agent (FBI & IRS-CI)

Maura Kelley

Former Special Agent (FBI)

Ray Yuen

Former Supervisory Special Agent (FBI)

Michael S. Koslow

Former Supervisory Special Agent (DOD-OIG)

Marquis D. Pickett

Special Agent U.S. Secret Service (ret.)

How We Help Healthcare Providers and Other Organizations with HRSA Audits

Our consultants assist healthcare entities before, during, and after HRSA audits. We routinely guide healthcare providers and other organizations through matters including;

1. Complying with the HRSA’s Audit Requirements for Grant Recipients

Submitting a compliant annual audit report (whether a Single Audit report or a financial audit report prepared according to the Government Auditing Standards) is critical for avoiding unwanted scrutiny from the HRSA. We work with our clients and their auditors to ensure that their audit reports meet all pertinent regulatory requirements. As even technical issues and oversights can raise red flags at the HRSA, it is imperative that grant recipients (and their auditors) put in the time and effort to ensure that they are comprehensively addressing all pertinent reporting and disclosure obligations.

In some cases, grant recipients’ annual audits will uncover billing violations and other deficiencies. When this happens, a proactive approach is critical. Before submitting their audit reports to the HRSA, grant recipients that have uncovered violations must take steps to demonstrate that both (i) the past violations have been thoroughly addressed, and (ii) they have taken adequate steps to prevent similar violations in the future. We assist our clients with these processes as well, and we have an extensive track record of helping healthcare providers avoid unnecessary consequences through a proactive, cautious, and strategic approach to disclosure and compliance.

2. Defending Providers and Other Organizations During the HRSA Audit Resolution Process

When the HRSA identifies red flags in a grant recipient’s Single Audit or financial audit report, it investigates its concerns through the audit resolution process. This process presents substantial risks for grant recipients, as findings that a recipient has improperly billed the HRSA can lead to:

• Drawdown restrictions
• Withholding of a percentage of the grant recipient’s federal funds
• Suspension of access to federal funds
• Reimbursement liability for drawdowns
• Termination of the recipient’s federal grant

During the audit review process, HRSA inspectors look for violations in three broad categories. Depending on their scope, severity, and cause, violations in each of these categories have the potential to lead to the consequences listed above:

• Management Findings – Management findings are those that either signify “[s]ignificant deficiencies in internal controls” or “[m]aterial noncompliance with laws, regulations, contracts, or grant agreements.” Managing findings often lead to systemic compliance failures; and, as a result, they will frequently expose healthcare providers and other organizations to significant penalties.
• Monetary Findings – Monetary findings are those that raise questions about the costs that a grant recipient has billed to the HRSA. This includes “[k]nown questioned costs cited in the audit report” as well as issues that the HRSA’s inspectors uncover during the audit resolution process.
• Repeat Findings – Repeat findings are those “that were identified in a previous Single Audit for which corrective actions have not yet been completed as planned.” The HRSA expects grant recipients to promptly correct all past compliance failures, and failure to do so can lead to adverse consequences.

We assist healthcare providers and other organizations with all aspects of HRSA audit resolutions. This includes dealing with the HRSA on behalf of our clients as well as working with our clients to proactively address apparent compliance failures. Here, too, a proactive and strategic approach is key, and we rely on our experience both as consultants and as former federal healthcare fraud investigators to advise our clients effectively.

3. Defending Providers and Other Organizations Facing Civil or Criminal Enforcement Action

Federal healthcare fraud is a major issue, and it is currently one of the federal government’s top law enforcement priorities. As a result, when an HRSA audit uncovers evidence of fraud, this can trigger immediate, intensive, and high-risk federal scrutiny.

In addition to assisting providers and other organizations during the HRSA audit process, we also consult with clients and their counsel during ensuring civil and criminal enforcement actions. This includes enforcement actions conducted by the U.S. Department of Health and Human Services’ Office of Inspector General (DHHS OIG), U.S. Department of Justice (DOJ), and other federal agencies. The HRSA inspectors share audit information with these agencies when they have concerns about civil or criminal fraud, and these agencies have substantial authority to gather additional information through document requests, civil investigative demands (CIDs), subpoenas, and other means.

While healthcare providers and other organizations can face grant-related penalties during the HRSA’s audit resolution process, the consequences of a healthcare fraud audit or investigation can be far greater. In civil enforcement actions, grant recipients can face civil monetary penalties (CMP), treble damages, and other costs in addition to the penalties listed above. In criminal enforcement actions, grant recipients can face substantial fines at the organizational level, and owners and executives can face both fines and prison time in some cases.

FAQs: Avoiding Unnecessary Consequences During an HRSA Audit

Speak with an HRSA Audit Consultant at Corporate Investigation Consulting

If you need to know more about how to deal with the HRSA’s audit process, we encourage you to contact us promptly. To arrange a complimentary initial consultation as soon as possible, call 866-352-9324 or contact us confidentially online today.