PYA Covid-19 Information Hub
Published August 13, 2020

When HHS Knocks at the Door—Preparing for Provider Relief Fund Attestation Defense

Questions were quickly queuing during a recent webinar, When HHS Knocks at the DoorPreparing for Provider Relief Fund Attestation Defense, presented by PYA and law firm Holland & Knight. The webinar drew a large audience of CEOs, CFOs, and compliance professionals seeking to understand the recent CARES Act Provider Relief Funds (PRF) audit guidance.

As usual, the term “audit” has many implications in healthcare. In this instance, it covers accounting, external financial audit/assurance, internal audit preparation, cost reporting, and regulatory compliance considerations. Each of these was triggered by providers’  acceptance of the terms and conditions that have continued to change since PRF first were distributed, and much still remains in question.

We are seeing consistent themes weighing on the minds of executives, including:

  • How do providers define and account for “lost revenue?”
  • What other sources of funding are assumed to be duplicative of PRF payments, including cost-based reimbursement, PPP payments to governmental-owned providers, insurance proceeds, payer reimbursement on COVID testing, etc.
  • Are the HHS reporting and audit requirements the same as the requirements for Single Audits for expenditures of government grant funding?
  • Can distributions be allocated between entities of an integrated system?
  • Are incremental audit, legal, and consulting services to meet these attestation, reporting, and auditing requirements allowable as “healthcare related expenses attributable to coronavirus?”
  • What is the time frame for which lost revenue and eligible expenses can be counted?
  • Can facility-related expenses to prepare for the continued management of this and future pandemic events be considered eligible expenses?
  • Can providers request payment or additional information from HHS related to target distributions?
  • What are the implications of the June 30 FYE audits?

Since March, members of PYA’s COVID-19 task force have been working daily with our clients on a broad range of issues providing advice, a sounding board, or research support depending on their specific needs. Given the multi-faceted impact on our clients, this task force comprises subject matter experts in regulatory compliance, government funding mechanisms, accounting, audit, tax, cost reporting, and provider operations.

We have found that just as no two providers are the same, the answers to and implications of providers’ specific questions are also not alike. Accordingly, we structure arrangements to help these providers with high-touch service in an economical platform.

View the on-demand webinar here. Answers to questions received during the webinar will be posted soon.

If your organization needs a partner as it navigates the PRF maze, PYA is available to assist. Visit PYA’s COVID-19 hub for additional resources and information, or contact a PYA executive below at (800) 270-9629.

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