However, each program is complex, and program terms and conditions continue to change and develop. COVID-19 relief programs, including the HHS Provider Relief Fund (PRF) and SBA Paycheck Protection Program (PPP), continue to clarify program terms and conditions, but many are still subject to interpretation, and even more are likely to change. The SBA indicated they will audit all entities receiving more than $2 million, and the HHS has indicated PRF receipts will be subject to single audits under the Uniform Guidance and could be subject to separate audits by the HHS, OIG or other oversight entities.

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