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Know the Rules
An Update on Compliance and Reporting for Provider Relief Funds
By James T. Krupienski, CPA
At the start of the COVID-19 pandemic in the early parts of 2020, the concern of business survival was the number-one thought of countless businesses, with each industry having its own struggles. The medical industry was not without its own real concerns at that time, particularly given its role in the pandemic fight. People would continue to get sick, require treatment, and see their physi- cians, but how could it be done safely?
took dramatic steps. In addition to Paycheck Pro- tection Program (PPP) loans, for which medical practices were eligible, the Coronavirus Aid, Relief and Economic Security (CARES) Act also allocat- ed funds directly to the medical industry through the Department of Health and Human Services (HHS) and the newly created Provider Relief Fund (PRF).
The first round of funding, which was com- pletely unexpected to many, occurred in early
medical, dental, and other healthcare-related practices during the pandemic, that support was not without certain compliance requirements and reporting, which we will dive into within this article.
First, within 90 days of receipt of the funds, each provider was required to attest to cer- tain terms of use. For those electing to return the funds, it was required to be done within
14 days of this attestation. Attestations were required for receipt of funds in all phases and were to be completed through use of a portal with the HHS ( act-provider-relief-fund/for-providers/index. html#how-to-attest).
As part of the attestation process, any provider receiving more than $10,000 in payments through the PRF would be required to report on use of the funds. While the specifics on the exact reporting took months to be finalized and continued to be reworked by the HHS, the general guidelines were
Continued on page 35
 “While the COVID-19 relief provisions, as part of the CARES Act, provided a lifeline for many medical, dental, and other health- care-related practices during the pandemic, that support was not without certain com-
April 2020, when $30 billion was depos- ited directly into the accounts of eligible practices. Through- out 2020, additional funds were later rolled out in phases 2 and 3, as well as through targeted dis- tributions to specific industries, such as rural providers and skilled-nursing facili- ties. Of importance is
     pliance requirements and reporting.”
Recognizing the financial crisis that was about to overtake this industry, along with how detri- mental it was for the industry to remain open and accessible to patients, the federal government
that, for all practices receiving these funds, there are several rules to be followed.
While the COVID-19 relief provisions, as part of the CARES Act, provided a lifeline for many
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