Yesterday the Health Resources and Services Administration (HRSA) sent out several notification emails with a records retention update for those records pertinent to Provider Relief Fund (PRF) grants. Many of these notices were not correctly directed at the provider who received the email, often referencing a different PRF recipient and Tax Identification Number (TIN).
Today HRSA has now sent out an additional notice that serves to correct the emails received in error by referencing the correct PRF recipient and TIN. The information in the updated notice itself confirms the information stated in the erroneous emails – the record retention requirement has arguably been extended.
The notice is seemingly intended to stretch the record retention period from the prior understanding. The retention period has generally been interpreted as three years from the date of the entity’s last PRF reporting obligation, based on language that is referenced in the Terms and Conditions of the award still on the PRF Reporting and Auditing FAQ page, stating: “Providers need to retain original documentation for three years after the date of submission of the final expenditure report, in accordance with 2 CFR 200.333.”
It appears that HRSA is establishing a broad definition of the “final expenditure report” and equating that date for all PRF recipients. As a result, HRSA seemingly established a national record retention timeline for all entities until September 30, 2027, utilizing the end of the last reporting period as the date from which the three-year requirement starts. This means that, for those PRF recipients who received and reported on funds in periods one through six, the record retention timeline has been extended beyond the three-year window initially anticipated. This notice also may signal intent by HRSA to allow flexibility in extending the audit window for HRSA-conducted programmatic audits and assessments until at least September 30, 2027.
Organizations should be prepared to retain relevant documentation until at least September 30, 2027, in the absence of any revised guidance or responses to provider-led challenges.
For help with grant funding and other matters, you can contact your Advis consultant for any further questions.
Published March 11, 2025
