Share
Preview
MAC Recommends Tracking How You Use All Funds Received
 ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌
CARES Act Provider Relief Fund Update
MAC Recommends Tracking How You Use All Funds Received


The MAC office has gotten questions about the CARES Act Provider Relief Fund and the possibility of audits from the Centers for Medicare and Medicaid Services down the road after the COVID-19 crisis has subsided. The CARES Act Provider Relief Fund page states:

The Terms and Conditions also include other measures to help prevent fraud and misuse of the funds. All recipients will be required to submit documents sufficient to ensure that these funds were used for healthcare-related expenses or lost revenue attributable to coronavirus. There will be significant anti-fraud and auditing work done by HHS, including the work of the Office of the Inspector General.


There are three things of note here:

  1. The funds are intended to be used for: (a) Healthcare-related expenses attributable to coronavirus, or (b) Lost revenue attributable to coronavirus
  2. It is likely (or at the very least possible) that in the future audits could be undertaken to ensure that monies from the Provider Relief Fund were used for these purposes
  3. All recipients will be required to document that the funds were used on either (a) or (b) above.


If You Receive ANY Funds, Document How Payments Are Spent!
The Terms and Conditions for the Provider Relief Fund require, no later than 10 days after the end of each calendar quarter, a recipient receiving more than $150,000 total in funds under the CARES Act, Coronavirus Preparedness and Response Supplemental Appropriations Act, Families First Coronavirus Response Act, or any other Act primarily making appropriations for the coronavirus response and related activities, to submit a report regarding the use of funds. The exact format of these reports has yet to be released; however, the Terms and Conditions state that the report shall contain:

  • The total amount of funds received from HHS under one of the foregoing enumerated Acts
  • 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 the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity (if applicable)
  • Detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees
  • Appropriate records, cost documentation, and other information to substantiate the reimbursement of costs

While this requirement only applies to those receiving more than $150,000, the quote above from the Terms and Conditions says: “All recipients will be required to submit documents…” Due to this uncertainty, the MAC recommends that if you receive ANY funds, you should immediately maintain appropriate records and cost documentation, making a meticulous record of all payments and disbursements associated with the funds received, should you need to justify your use of funds in an audit defense sometime in the future.

Track Expenses and Lost Revenue
  • Immediately begin tracking expenses due to the coronavirus. This could include increased cleaning costs, costs associated with modifying waiting or patient rooms to ensure social distancing, the cost of providing masks or other PPE to staff, etc.
  • Immediately document all lost revenue attributed to coronavirus. This could include such indirect costs as a decline in visits due to only seeing patients to protect or sustain life, a reduction in the number of procedures such as massage or other physical medicine procedures, etc. Lost revenue could be estimated by comparing year-over-year revenue, or by comparing budgeted revenue to actual revenue.

As we have mentioned in other MAC articles regarding government loans and other programs, you may want to establish a separate bank account and set up a separate ledger/accounting system to track payments.


Disclaimer: The Michigan Association of Chiropractors is a professional association advocating for the rights of chiropractors and their patients across the state of Michigan. We are NOT a state agency or regulatory body. We are merely informing our membership regarding what they are allowed to do during this difficult and confusing time.

The information we provide during this pandemic is derived in conjunction with our governmental relations and legal experts, developed after examination of all official releases of information from the State of Michigan and in consultation with said experts and representatives from state government. Please refer to our emails and website for the latest information, free from speculation and the rumors currently circulating in the wake of official state actions.

Rest assured that we will continue to advocate for the profession at the highest levels, with the health and well-being of you and your patients, as well as the overall stability of the health care system, foremost in our efforts.

 
 
 

Email Marketing by ActiveCampaign