The healthcare industry is entitled to a hefty portion of relief under the Coronavirus Aid, Relief, and Economics Security (CARES) Act and other federal Coronavirus Acts. Built into this legislation are strict oversight provisions to ensure the funds are being used appropriately.
If your organization is the recipient of more than $150,000 of these funds, it will be required to submit reports to the Secretary of the Pandemic Response Accountability Committee (PRAC) no later than 10 days after the end of each calendar quarter. The mechanism for filing these reports has not yet been indicated.
The reports must contain:
- The total amount of funds received from HHS Provider Relief Fund
- The amount of funds received that were expended or obligated for each project or activity
- A detailed list of all projects or activities for which large covered funds were expended or obligated, including: (1) name and description of the project or activity and estimated number of jobs created or retained by the project or activity, where applicable; and (2) detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, including the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006
Compliance with this reporting obligation will require meticulous and appropriate records and cost documentation. The PRAC Secretary can request this documentation at any time, and fund recipients are subject to audits by the Secretary, Inspector General or PRAC to ensure compliance with funding terms.
Grassi Healthcare Advisors is helping affected providers prepare a three-step process for successful compliance:
- Develop an initial detailed plan with activities to utilize the funds for specific projects that mitigate the impact of COVID-19.
- Establish a process for collection of financial data on expenditures tied to each of these activities on a monthly basis.
- Compile and submit reports to the PRAC no later than 10 days following the end of each quarter.