Provider Relief Fund recipients subject to reporting, auditing
WAILEA, Hawaii — Practices that received funds related to COVID-19 relief will now have to deal with reporting and possible audits of spending.
“Money doesn’t grow on trees, and it is never for free. So, if you got PRF money, I am sure you are dealing with the headache of the changing rules,” Allison W. Shuren, JD, MSN, told the Hawaiian Eye 2021 audience here.
Since the day Provider Relief Fund (PRF) checks went into practice bank accounts, the regulations that “impact you and how you got to keep the money, records you were going to need to give the government on how you used it” evolved and emerged, although with the change in presidential administration, these rules are being reviewed, and “so we are in sort of a holding pattern,” she said.
Shuren, who is a partner at Arnold & Porter and co-chairs the Life Sciences and Healthcare Regulatory practice, told the audience if they received and kept more than $10,000, they will be subject to reporting and possibly auditing.
She said fund recipients must register at the Provider Relief Fund Reporting Portal. The portal is the only way providers can receive real-time information from the government about when reporting opens and what must be reported.
If a practice received more that $500,000 from the Provider Relief Fund, there is extensive reporting, and they are likely to be audited. In addition, if a practice received more than $750,000 combined from all federal health care relief programs, such as Paycheck Protection Program, FEMA CARES Act and CARES Act Testing, “you will have one single audit that is under the government auditing standards,” Shuren said. “So, if you are in that category and do not have a CPA working with you who understands federal grant money auditing, then you need to get someone on your team that knows how to do that.”
“The last thing you want to do is mistakenly be submitting reports to the government that do not meet their standards, do not have the right information for that audit and find yourself across the table from an HHS agent asking you questions about what you did with the money,” Shuren said.
For those who received less than $500,000, reporting is straightforward, she said. More than $750,000 reporting includes items such as general and administrative expenses and health care-related expenses that involve dealing with COVID-19, such as mortgage/rent, supplies, equipment, IT and much more.
“Hopefully, you have had a team already keeping these documents for you and keeping very good ledgers of what you spent Provider Relief Fund money on because you are going to have to prove to the government how you spent it and that you spent it within the rules,” Shuren said. “Or else they are going to come back with their big claw and take it back from you.”
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Shuren AW. Healthcare law in the new normal: What just happened? Telehealth view, human resources post-COVID-19, physician contracting and how salary addendums were handled. Presented at: Hawaiian Eye; May 8-14, 2021; Wailea, Hawaii.
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