Since the early stages of the COVID-19 pandemic, Congress and the federal government have committed massive amounts of money to economic recovery across affected industries, with healthcare receiving hundreds of billions of dollars in emergency funding. Despite this push to inject capital into a shuttered economy, healthcare organizations have gotten surprisingly little in the way of direction on how they could spend these monies. Providers—a few of which are flush with cash and many struggling with a lack of working capital—now grapple with questions about how to spend sizeable sums of stimulus money legally and how to get their organizations on the road to recovery. Meanwhile, they wait for more guidance, knowing the inevitable waves of audits and enforcement are coming.
During this webinar, you will learn the following:
- How to appropriately receive and optimize COVID-19 relief funding.
- How to utilize relief funding in a compliant way.
- How to proactively prepare for audit and oversight.
- How to make data-informed decisions to prepare, prevent, recover, and plan during a global pandemic.
5. Common COVID Relief Funding Sources
Accelerated & Advance Payment Program
Centers for Medicare and Medicaid Services (CMS)
Provider Relief Fund (PRF)
Health and Human Services (HHS)
Coronavirus Relief Fund (CRF)
US Department of the Treasury (Treasury)
COVID-19 Telehealth Program
Federal Communications Commission (FCC)
Category B Public Assistance
Federal Emergency Management Agency (FEMA)
6. $175 Billion
CARES Act and PPP & Healthcare Enhancement Act Appropriations to
HHS for the Provider Relief Fund (PRF)
7. Provider Relief Fund (PRF) Distributions
As of October 10, 2020
$50.0
$18.0
$20.0$22.0
$11.3
$4.9
$0.5
$13.3
$5.0
$1.4
$28.6
HHS Provider Relief Fund (in billions)
GENERAL DISTRIBUTION, PHASE 1 GENERAL DISTRIBUTION, PHASE 2
GENERAL DISTRIBUTION, PHASE 3 HIGH-IMPACT DISTRIBUTION
RURAL DISTRIBUTION ALLOCATION FOR SNFS
ALLOCATION FOR TRIBAL HOSPITALS, CLINICS AND URBAN HEALTH CENTERS ALLOCATION FOR SAFETY NET HOSPITALS
ALLOCATION FOR NURSING HOMES ALLOCATION FOR CHILDREN'S HOSPITALS
REMAINING, INCLUDING TREATMENT FOR UNINSURED COVID-19 PATIENTS
8. • Lost revenues
• Calculation and limits on use of lost revenue
• Healthcare related expenses attributable to Coronavirus
• Expense-first order in supporting PRF dollars received
• Unanswered questions
The Latest Guidance from HHS*
* Post-Payment Notice of Reporting Requirements, PRF General and Targeted Distribution, October 22, 2020.
9. • Step 1: Healthcare related expenses attributable to Coronavirus that
another source has not reimbursed:
• General and administrative (G&A)
• Healthcare related operating expenses
• Step 2: PRF payment amounts not fully expended on healthcare related
expenses attributable to coronavirus are then applied to patient care lost
revenues.
Reporting Guidance on Use of Funds
Recipients will report their use of PRF payments using their normal method of
accounting (cash or accrual basis), by submitting the following information:
10. G&A Expenses Attributable to COVID-19
Fringe Benefits
The actual G&A expenses incurred over and above what has been reimbursed by other sources.
Lease Payments Utilities/Operations
Mortgage/Rent
Insurance Personnel
Other G&A
11. Expenses paid to prevent, prepare for or respond
to the Coronavirus during the reporting period:
• Supplies: PPE, hand sanitizer or supplies for patient
screening
• Equipment: Ventilators, updates to HVAC systems, etc.
• Information Technology (IT): Expenses paid for IT or
interoperability systems to expand or preserve care
delivery during the reporting period, EHR licensing fees,
telehealth infrastructure, increased bandwidth, and
teleworking to support remote workforce
• Facilities: Lease or purchase of permanent or temporary
structures or to modify facilities to accommodate patient
treatment practices revised due to Coronavirus
• Other Healthcare Related Expenses: Any other expenses
not captured above
Healthcare Related Expenses Attributable to COVID-19
Actual healthcare related expenses incurred over and
above what has been reimbursed by other sources
12. Lost Revenue Attributable to COVID-19
• Lost revenues attributable to coronavirus are
represented as a negative change in year-
over-year actual revenue from patient care
related sources. Other assistance received is
reported as operating revenue and used in
the calculation of year-over-year change in
patient care related revenue.
• If recipients do not expend PRF funds in full
by the end of calendar year 2020, they will
have an additional six months in which to
use remaining amounts toward expenses
attributable to coronavirus but not
reimbursed by other sources, or to apply
toward lost revenues in an amount not to
exceed the difference between 2019 and
2021 actual revenue.
14. • Reporting system will become available January 15, 2021.
• All recipients must report by February 15, 2021 on expenditures
through December 31, 2020.
• For any funds not used by December 31, 2020, a second and final
report will report will be due by July 31, 2021.
• HHS published guidance on September 19, 2020 and October 22,
2020, and more Q&A sessions and FAQs are promised.
HHS PRF Reporting Requirements
15. What Is a Single Audit?
• A single audit encompasses:
• Financial statement audit in accordance with AICPA standards (GAAS) and
Government Auditing Standards (known as Yellow Book or GAGAS)
• Compliance audit in accordance with GAAS and the Uniform Guidance
• Generally must be performed annually when a nonfederal entity
expends $750,000 or more of federal awards (either direct or
indirect awards) in their fiscal year
• Must be submitted to the Federal Audit Clearinghouse within the
earlier of:
• 30 days after receipt of the auditor’s reports; or
• 9 months after the end of the audit period
16. • Have a draft Schedule of Expenditures
of Federal Awards (SEFA) ready
• Include reconciliation of SEFA, financial statements
and other SEFA supporting documentation
• Have readily accessible written
policies and procedures.
• Provide the auditor with access to
personnel, accounts, books, records,
supporting documentation and other
information as needed.
• Identify and address problem areas in
advance and communicate with your
auditor in the early stages on any
known issues.
Audit Strategy
17. • Financial survival
• Short-term cash flow pressures
• Staffing challenges
• Fixed cost structure not allowing overall costs to drop commensurate
with revenue
• Evaluating and tracking funding
opportunities
Common Immediate Issues
18. • Stimulus dollars likely far short of impact
• Continue documenting COVID-19 related care
• Restating selected services
• Potential pent up demand—but patient wariness of COVID-19 free
environment
• Strategy for expense management
• Greater self-pay with unemployed
• Legal support
Recovery Planning
20. Permanent Team Temporary Project Team
Team Structure Thoughts
• Pros
• Proactive
(strategic Commitment)
• Predictable Resource
Investment
• Team members expect
long-term relationship
• Members learn clinical or
operational domain
• Partnerships established
on priorities
• Cons
• “Feels” Too Heavy
• Cons
• Reactionary
• Variable
• Follow Up much slower
• Team members don’t always
understand context within domain
(confusion)
• Tendency to pile-on
• Pros
• Easier to get rolling
21. COVID-19EmergencyFundingRoadMap&BestPractices
1. Adapt and Execute
Relief Funding Plan
a.Finalize decisions on existing
sources
b.Maximize current relief funds
c.Monitor new rounds of
funding
2. Empower compliance
Team
a.Study ever-changing
requirements and guidance
b.Refine reporting strategy
c.Test and revise controls as
needed
a.Finalize documentation
b.Reconcile funds and resources
c.Execute readiness plan
a.Prepare for post-COVID case and payer mix
b.Develop virtual care and brick-and-mortar strategies
c.Consider new competitors and consolidation
d.Capitalize on changes in patient migration patterns
5. Engage Your Leadership in
Post-COVID Strategies
3. Respond to Oversight
05
4. Adopt Insight-Driven
Strategies with Data
a.Find and gather core business data
b.Identify and avoid information
biases
c.Employ fact-based decision making
6. Imagine What’s Possible
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COMMUNICATE AND TRAIN OFTEN
STEWARD RESOURCES
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