Your health center may have been fortunate in receiving an influx of funding from several federal stimulus sources in response to COVID-19, such as HRSA COVID-19 funding, Provider Relief Funds, Uninsured Program Portal funding, and perhaps even additional funding such as support from the Federal Communications Commission (FCC) COVID-19 Telehealth Program. While this additional support provides a substantial benefit to helping your center maintain capacity through any future COVID-19-related impacts to business, it also comes with terms, conditions, and regulatory guidance that must be followed. Keep these considerations in mind as you navigate use of these additional funding sources.
1. Be sure that your health center is clear on the spending timelines and reporting requirements for the usage of funds.
Provider Relief Fund guidance was updated as of Jan. 15, 2021, and the Provider Relief Fund Reporting Portal was opened for registration. All entities that have received $10,001 or more in the aggregate must register in this portal. Currently, there is no deadline that HHS has mandated for completing this registration. PRF recipients will receive an email notification about when they should complete the submission of the required reporting information on the usage of the funds. Registration should be completed as soon as possible to ensure that timely communication is received from HHS. Providers will have an additional opportunity to report by July 31, 2021, on the usage of funds not expended prior to Dec. 31, 2020. The Jan. 15 update to the Post-Payment Notice of Reporting Requirements included additional guidance as to reporting on expenses attributable to COVID-19 and lost revenues. Provider Relief Fund FAQs are posted frequently; be sure to check the HHS website for updates on a regular basis.
2. Have you implemented sufficient procedures for tracking use of funds?
Use of all funding streams will need to be diligently documented so that when reporting on the use of funds, you will be able to clearly show that multiple funding streams were not being used for the same expenses – that you didn’t engage in any “double-dipping.” This will also facilitate the reporting that will ultimately have to be done for all funding streams to confirm that you have used funding aligned with the terms and conditions on usage. Expenses charged to each funding source should be clearly documented in the accounting records to stand up to audit.
3. Have you strategically planned how you are going to prioritize?
Each federal funding stream received in response to COVID-19 has different permissible uses for funds and timelines during which funds can be spent. Have you examined your operating expenses since the pandemic hit or projected continued impact from COVID-19 to determine how best to allocate funds? Are you prioritizing fund use from the sources that are most restrictive, and with the shortest timeframe during which to spend down funds, to those that are least restrictive, so that you can make sure you have additional support available in the event of a second or third wave of COVID-19 impact to your business?
4. Have you considered Uniform Guidance Single Audit implications?
Community Health Centers were eligible for various government funding opportunities, several of which are subject to audit as part of the Center’s annual Single Audit. Centers have received three COVID-19-related HRSA grants thus far in addition to base grant funding – H8C, H8D, and H8E Awards – and have been assigned the Catalog of Federal Domestic Assistance (CFDA) number 93.224, which is part of the Community Health Center Cluster Program. Although all of these awards have the same CFDA number, they each have different grant numbers, requiring the submission of separate Federal Financial Reports (FFRs – SF-425). Community Health Centers are expected to track the related expenditures for each individual grant and maintain the related documentation to support the basis of recognition.
The FCC COVID-19 Telehealth Program (CFDA 32.006) is a federal award that is subject to Single Audit. Subparts B (General Provisions), E (Cost Principles), and F (Audit Requirements) of the Uniform Guidance are applicable to this program. The program is not considered a grant program. Health centers that are approved for funding must submit an invoice and supporting documentation in order to receive reimbursement for the eligible expenses and services provided. This program is subject to certain compliance requirements as identified in the Office of Management and Budget (OMB) 2020 Compliance Supplement Addendum.
Provider Relief Fund General and Targeted Distributions payments (CFDA 93.498) and Uninsured Testing and Treatment reimbursement payments (CFDA 93.461) are also federal awards and subject to Single Audit. Subparts B (General Provisions), D (Post Federal Award Requirements), E (Cost Principles), and F (Audit Requirements) of the Uniform Guidance apply to Provider Relief Funds. Provider Relief Funds are subject to certain compliance requirements as identified in the Office of Management and Budget (OMB) 2020 Compliance Supplement Addendum. HHS will be releasing guidance at a later date with instructions as how to prepare the Provider Relief Fund Report, which will identify the amount of Provider Relief Funds earned and be the source of information that will be required to be disclosed on the Schedule of Expenditures of Federal Awards (SEFA) in relation to the Single Audit Report.
CohnReznick is prepared to support health centers as they not only work toward compliance but also identify opportunities to enhance revenue maximization. Our team can:
- Identify best practices to track use of all COVID-19-related funds and avoid “double-dipping” concerns
- Assist in strategic financial planning on how to utilize all Provider Relief Funds and COVID-19-related funding and maximize full revenue potential
- Educate your team on the compliance and reporting requirements related to Provider Relief Funds and COVID-19-related funding
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