You suspected that the government money you accepted from the HHS Emergency Relief Fund came with strings attached but you may not have realized how hard grasping the details would be.
Your practice could be one of the many new ones that has mandatory reporting requirements based on a new HHS August notification. Find out five critical answers on the latest obligations for avoiding paying back your loan. HHS relief fund reporting.
What Rules Guidance Was Pushed Back?
HHS delayed releasing its full rehauled reporting instructions that you must comply with to hold onto more of your money. CMS had committed to issuing the new HHS reporting specifics on Aug. 17. Last week, the agency announced that now it plans to publish the new rule “well in advance” of October 1. While further guidance is pending, there are several changes that impact you now.
Does Your Practice Need to File a Report?
A lot of practices are now on the hook for fulfilling filing obligations. If your practice received Provider Relief Fund payments of more than $10,000, you must submit a report detailing how you used your money. Previously, you only had to file a report if you had received more than $150,000 in funds.
What Funds Can You Record?
Under your allowed expenses, you can include items and services you purchased to prevent, prepare for, and respond to coronavirus, including:
- Supplies and equipment used for possible or actual COVID-19 patients
- Training staff on COVID-19 prevention and disinfection protocols
- Emergency operations centers development and staffing
- COVID-19 test results reporting to federal, state, or local governments
- Temporary structures building or construction to expand COVID-19 patient care capacity or to provide services to non-COVID-19 patients in a separate area from COVID-19 patients (e.g., covered parking lots for COVID-19 testing separate from usual practice parking)
- Additional care delivery expansion and preservation resources such as facilities, equipment, supplies, healthcare practices, staffing, and technology
How Should You Document Your Expenses?
You’ll get the new instructions plus a data collection template sometime in September, according to the HHS announcement.HHS relief fund reporting.
Are There Consequences If You Miss a Condition?
CMS will be auditing records against their terms and conditions notices. Any misappropriation or misuse will be docked against your funds – and you’ll have to give back some or all of your money.
You can face other legal action too. Penalties including Medicare disbarment, fines and imprisonment are all potential repercussions of deliberate omission, misrepresentation, or falsification of report information. HHS relief fund reporting.
When Do You Need to File One or More Reports?
The new reporting timeframes are really confusing. You might need to file one report this year or early next year and a second report next July. The notification indicates everyone above the $10,000 threshold must file at least once.HHS relief fund reporting.
You better be consistently tracking all of your expenses and losses through the end of the year. That will make your work gathering, auditing, and completing the new template to submit by Feb 15, 2021, a lot less cumbersome and much more accurate.
Then it is unclear if you will need to file an additional report. Hopefully, the new rules will make the below guidance clearer:
- If you use up all your funds by Dec. 31, file a single final report between Oct. 1, 2020 and Feb. 15, 2021.
- When your practice has unused money after Dec. 31, submit a second report by July 31, 2021.
For a step-by-step walk through of the new fund rules so you can maximize the amount of money you get to keep – and prevent penalties, healthcare attorney, Kristyn DeFillip, Esq, is going to tell you how during her upcoming online training “New HHS Rule: Avoid Losing Your COVID-19 Emergency Relief Money.”
Sources:
- Provider Relief Fund Reporting Requirements and Auditing
- HHS August Notice of Post-Payment Reporting Requirements
