Audits are now underway for proper use of funds, even as the reporting deadline approaches.
Many healthcare providers were recipients of provider relief funds (PRFs) during the COVID-19 pandemic. If providers received these funds, there were reporting requirements and use requirements. Now, audits are being conducted to ensure the funds’ proper use and reporting. Audits are being rolled out on two different fronts: by the U.S. Department of Health and Human Services (HHS) and the Health Resources Services Administration (HRSA).
On Feb. 25, 2022, the American Institute of Certified Public Accountants (AICPA) Government Audit Quality Center (GAQC) provided long-awaited guidance to for-profit healthcare organizations that are subject to the PRF audit requirements. The guidance came in the form of a practice aid titled HHS Audit Requirements for For-Profit Entities with Awards from the Provider Relief Fund Program and Other HHS Programs. Its goal was to provide clarity to for-profit healthcare entities that expended $750,000 or more in federal awards in a given reporting period, which includes the PRF, and other federal awards included in the Assistance Listing, but excludes Paycheck Protection Program funds.
Based on the practice aid, here is a summary of audit options available to for-profit entities to meet the HHS audit compliance requirements.
There are four reporting periods that will be audited. Reporting for the fourth period is going on now. Providers that received a PRFs (General or Targeted) exceeding $10,000 in the aggregate from July 1, 2021 to Dec. 31, 2021, are required to report on their use of funds during the fourth period. The deadline to submit a report is March 31, 2023.
There is an appeal process if you receive a Final Repayment Notice. Once you receive a Final Repayment Notice, you have 60 days to either pay or appeal.
HRSA cannot establish payment plans for outstanding debts. Once the repayment amount has been referred to PSC and becomes official debt, providers can apply for repayment plans directly with PSC.
The Centers for Medicare & Medicaid Services (CMS) has the authority to recoup alleged overpayments from healthcare providers before the full adjudication of an appeal.
Since Jan. 20, it seems that uncertainty in healthcare has become the new normal. After a contentious hearing, Robert F. Kennedy, Jr. was appointed to
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