The document provides information for dental providers about the Provider Relief Fund, which was created by the CARES Act to provide financial assistance to healthcare providers responding to COVID-19. Key points include:
- There are important application deadlines of July 20 for Medicaid/CHIP funds and July 24 for dental provider funds.
- Dental providers must meet eligibility criteria to apply for targeted allocation funds by July 24, including not receiving other relief funds and providing patient care after January 31, 2020.
- Providers must manage funds properly by reviewing terms, establishing accounting and documentation, and preparing for reporting requirements to avoid potential recoupment of funds if expenses cannot be justified.
You’ve Received COVID-19 Related Federal Assistance – Now What?Citrin Cooperman
In this webinar, we discussed the complex web of audit and reporting considerations that organizations who received COVID-19 related federal assistance must consider as they approach year-end planning and look forward to 2021.
CARES Act Update - What you Need to Know Heading into 2021Citrin Cooperman
During this webinar we focused on the interplay between the different CARES Act provisions, in particular PPP loans, Provider Relief Funds, and Medicare Advanced Payments, and how they may impact 2020 year-end planning and 2021 forecasting.
You’ve Received COVID-19 Related Federal Assistance – Now What?Citrin Cooperman
In this webinar, we discussed the complex web of audit and reporting considerations that organizations who received COVID-19 related federal assistance must consider as they approach year-end planning and look forward to 2021.
CARES Act Update - What you Need to Know Heading into 2021Citrin Cooperman
During this webinar we focused on the interplay between the different CARES Act provisions, in particular PPP loans, Provider Relief Funds, and Medicare Advanced Payments, and how they may impact 2020 year-end planning and 2021 forecasting.
The New Rage in SALT: State Pass-Through Entity TaxCitrin Cooperman
During this webinar, Partner Eugene Ruvere and Principal Jaime Reichardt take deeper dive into the new elective tax regime in New York, in addition to neighboring states like Connecticut, New Jersey, and Rhode Island, among others.
C-Suite Snacks Webinar Series: Tax Structures to Reduce Cost and Improve Comp...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Running a business can be quite difficult, and the process of getting things up and running often overshadows other considerations, such as what type of business tax structure you should operate under. During this session, we covered how to structure your business for optimal tax benefits. Key takeaways included:
- Best tax structure for your business
- New insights on tax structure
- Tips to avoid tax traps based on the type of structure
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
High Net Worth Webinar Series: SALT Thoughts - Pass-Through Entity Taxes & Re...Citrin Cooperman
During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
C-Suite Snacks Webinar Series: There’s No Vaccine for This - State and Local ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The pandemic has affected everything in our lives, all the way down to how we run our businesses and our personal finances. In this session, State and Local Tax Partner Eugene Ruvere covered business and personal income tax considerations connected to the pandemic.
The Tax Cuts and Jobs Act has now passed, which enacts the biggest tax reform law in thirty years. Citrin Cooperman's Federal Tax Policy Team recently hosted a webinar discussing what you need to know to begin planning and steps you can be taking to be prepared. The conversation focused on the following key areas:
Business
Corporate
Pass-Through Entities
International
Individuals
State and Local Implications
Understanding Single Audit Compliance Requirements - It's No Joke!Citrin Cooperman
Has your not-for-profit organization received federal funding or additional funding under the CARES Act? This informational session discussed audit requirements for organizations receiving federal funds (i.e. Single Audits), reporting considerations, and specific requirements relative to COVID-19 response funds, including Paycheck Protection Program loans, Economic Injury Disaster Loans, Provider Relief Funds, and more.
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in Philadelphia to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies. Join us to get answers to questions in the following areas:
Corporate and Businesses
Pass-Through Entities
International Issues
Individuals
High Net Worth Webinar Series - Estate Planning Strategies and UpdatesCitrin Cooperman
There’s much uncertainty in the world of estate planning for high net worth individuals and their families. With numerous legislative proposals that would drastically alter the current estate planning landscape, listen in as our Trust and Estate Services Practice team discusses: various proposals, including those in Congress and the Biden Administration’s Green Book, estate and gift planning strategies for the remainder of tax year 2021, and more.
The Long Lasting Impact of Tax Reform- NYC- Event- 1/24/18Citrin Cooperman
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in NYC to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies.
Practical Steps for Managing Provider Relief Fund DistributionsCitrin Cooperman
Our Healthcare Practice professionals participated in a webinar discussion, "Practical Steps for Managing Provider Relief Fund Distributions," for healthcare organizations.
Topics included: Provider Relief Fund Overview Managing Provider Relief Funds Eligibility Fund Usage & Risk Management Tracking, Documentation, and Reporting Tax and Audit Considerations Sector-Specific Considerations Post-Acute Providers Dental Providers
The New Rage in SALT: State Pass-Through Entity TaxCitrin Cooperman
During this webinar, Partner Eugene Ruvere and Principal Jaime Reichardt take deeper dive into the new elective tax regime in New York, in addition to neighboring states like Connecticut, New Jersey, and Rhode Island, among others.
C-Suite Snacks Webinar Series: Tax Structures to Reduce Cost and Improve Comp...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Running a business can be quite difficult, and the process of getting things up and running often overshadows other considerations, such as what type of business tax structure you should operate under. During this session, we covered how to structure your business for optimal tax benefits. Key takeaways included:
- Best tax structure for your business
- New insights on tax structure
- Tips to avoid tax traps based on the type of structure
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
High Net Worth Webinar Series: SALT Thoughts - Pass-Through Entity Taxes & Re...Citrin Cooperman
During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
C-Suite Snacks Webinar Series: There’s No Vaccine for This - State and Local ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The pandemic has affected everything in our lives, all the way down to how we run our businesses and our personal finances. In this session, State and Local Tax Partner Eugene Ruvere covered business and personal income tax considerations connected to the pandemic.
The Tax Cuts and Jobs Act has now passed, which enacts the biggest tax reform law in thirty years. Citrin Cooperman's Federal Tax Policy Team recently hosted a webinar discussing what you need to know to begin planning and steps you can be taking to be prepared. The conversation focused on the following key areas:
Business
Corporate
Pass-Through Entities
International
Individuals
State and Local Implications
Understanding Single Audit Compliance Requirements - It's No Joke!Citrin Cooperman
Has your not-for-profit organization received federal funding or additional funding under the CARES Act? This informational session discussed audit requirements for organizations receiving federal funds (i.e. Single Audits), reporting considerations, and specific requirements relative to COVID-19 response funds, including Paycheck Protection Program loans, Economic Injury Disaster Loans, Provider Relief Funds, and more.
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in Philadelphia to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies. Join us to get answers to questions in the following areas:
Corporate and Businesses
Pass-Through Entities
International Issues
Individuals
High Net Worth Webinar Series - Estate Planning Strategies and UpdatesCitrin Cooperman
There’s much uncertainty in the world of estate planning for high net worth individuals and their families. With numerous legislative proposals that would drastically alter the current estate planning landscape, listen in as our Trust and Estate Services Practice team discusses: various proposals, including those in Congress and the Biden Administration’s Green Book, estate and gift planning strategies for the remainder of tax year 2021, and more.
The Long Lasting Impact of Tax Reform- NYC- Event- 1/24/18Citrin Cooperman
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in NYC to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies.
Practical Steps for Managing Provider Relief Fund DistributionsCitrin Cooperman
Our Healthcare Practice professionals participated in a webinar discussion, "Practical Steps for Managing Provider Relief Fund Distributions," for healthcare organizations.
Topics included: Provider Relief Fund Overview Managing Provider Relief Funds Eligibility Fund Usage & Risk Management Tracking, Documentation, and Reporting Tax and Audit Considerations Sector-Specific Considerations Post-Acute Providers Dental Providers
Webinar: Free Money with Strings Attached – Cares Act Considerations for Fron...PYA, P.C.
PYA, in conjunction with the Montana Hospital Association, recently co-hosted a Frontier States Town Hall Meeting webinar, “Free Money With Strings Attached: CARES Act Considerations for Frontier States’ Healthcare Provider Organizations.” Principals Lori Foley, Martie Ross, and David McMillan introduced the CARES Act Provider Relief Fund including distribution formulas, the attestation process, the verification and application process, and ongoing recordkeeping requirement. They also answered attendees’ numerous questions regarding these matters.
Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, W...PYA, P.C.
The federal government is now making CARES Act Relief Fund payments to Medicare providers. These payments are not loans—they do not have to be repaid or forgiven. However, this money comes with strings attached.
During PYA’s 30-minute webinar, Provider Relief Fund Payments—What We Know, What We Don’t Know, What To Do Now, PYA Principals Martie Ross and Lori Foley discussed:
The source of the funds.
The required attestation process.
Compliance, tax, and audit concerns.
The webinar took place Friday April 17, 2020.
Medicare Bad Debt Checklist and Recent ClarificationsPYA, P.C.
PYA Senior Consultant Holly Bizic presented “Medicare Bad Debt Checklist and Recent Clarifications.” The presentation reviews:
Key facts and expectations.
Progression of Medicare bad debt policy.
Recommendations for compiling and defending bad debt listings.
Audit and desk review clarifications.
Benchmarking.
Webinar: “Trick or Treat? October 22nd Revisions to Provider Relief Fund Repo...PYA, P.C.
On October 22nd, the Department of Health and Human Services released revised Provider Relief Fund (PRF) reporting requirements. Under HHS’ September 19 directive, “lost revenue” was defined narrowly as a negative change in year-over-year patient care operating net income. Now, HHS will permit providers to use PRF funds to cover the difference between their 2019 and 2020 actual patient care revenue with some adjustments for COVID-related expenses. The October 22nd notice is available here.
PYA Principals Martie Ross and Michael Ramey hosted a complimentary 30-minute webinar, “Trick or Treat? October 22nd Revisions to Provider Relief Fund Reporting Requirements” on Thursday, October 29th.
The following Health Reform Checklist is intended to guide you through the general compliance requirements of
t he Affordable Care Act (ACA) as you prepare now for 2015 and beyond.
In general, these items apply to all employers.
In this webinar, CARES Act Funding and Single Audit Update, Withum’s Devin Desmond and Jennifer Stewart discuss recent developments related to Coronavirus Aid, Relief and Economic Security (CARES) Act funding in addition to revisions to Uniform Guidance and Single Audit implications. Viewers are able to identify recent developments related to CARES Act funding and better understand revisions to Uniform Guidance and impact on Single Audits.
“CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting”PYA, P.C.
PYA Principal Martie Ross spoke at the virtual North Carolina Healthcare Association Critical Access Hospital Statewide Meeting. The two-day event, “Quality Focus is a Finance Focus,” provided critical access hospital leaders with the opportunity to network and review data-informed strategies as well as updates to the Medicare Flexibility Program Project. It also provided guidance on federal compliance and tracking of Provider Relief Funds.
In “CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting,” Martie gave an overview of the history of distribution of those funds as well as regulations and guidelines including:
Statutory Language
Reporting Requirements
Use of Funds Calculation
Expenses
Risk Management
Martie presented Thursday, March 4, 2021.
If you would like guidance related to Provider Relief Fund regulations, or for assistance with any matter related to strategy and integration, compliance, or valuation, contact one of our PYA executives at (800) 270-9629.
Pandemic Heroes Compensation Act - Overview and Key RisksJasonSchupp1
The Pandemic Heroes Compensation Act (HR 6909) as introduced on May 15 draws heavily from the framework established for the September 11th Victims Compensation Fund. The main objective of the program is to efficiently deliver no-fault compensation to essential workers and their family members who have contracted COVID-19. This presentation provides an overview of the proposal and identifies key risks.
On-Demand Webinar: Compliance With New Provider Relief Funds Reporting Requir...PYA, P.C.
On September 19, the Department of Health and Human Services (HHS) published its Post-Payment Notice of Reporting Requirements. The Notice details the reporting requirements for all Provider Relief Fund (PRF) recipients that have received $10,000 or more in aggregate payments.
Under the PRF Terms and Conditions, a recipient may use the funds only for healthcare-related expenses and lost revenue attributable to coronavirus. The Notice provides the clearest direction to date regarding permissible uses of PRF funds.
PYA offered a 45-minute complimentary webinar that explained the new reporting requirements and delved into permissible uses. While many questions remain, we provided practical advice on the next steps in the reporting process.
The webinar took place Monday, October 5 at 11 a.m. EDT.
Health Reform: Interim Guidance on Expatriate Plans; Updates on ACA Reportin...CBIZ, Inc.
This Health Care Reform Bulletin provides information on the following topics:
a. Interim Guidance on Expatriate Health Coverage
b. Updates on Section 6055/6056 Reporting
i. Revised and Increased Reporting Penalties
ii. E-filing requirements for Employers
c. Final Rules: Preventive Services
d. Reminder on PCOR Fees and Transitional Reinsurance
i. Checklist for PCOR and Transitional Reinsurance Fee
Webinar: “Making It Work—Physician Compensation During the COVID-19 Pandemic”PYA, P.C.
What to do with your physician compensation plan in the face of the COVID-19 pandemic? It’s a question that leaves administrators searching for answers.
PYA Principal Angie Caldwell and Senior Manager Katie Culver introduced several key considerations for provider compensation during and after the COVID-19 pandemic. In PYA’s complimentary webinar, they:
Summarized the current environment impacting physician compensation associated with the pandemic.
Provided an overview of the Stark Blanket Waivers and opportunities created for physician compensation.
Described restoration and recovery strategies for physician resources.
PYA hosted this one-hour webinar Tuesday, April 28, 2020, at 11 a.m. EDT in conjunction with the Florida Hospital Association.
During this webinar the Direct Contracting Model Options team hosted a webinar on Tuesday, January 7, 2020 from 1:00 p.m.- 2:30 p.m. EST. During this webinar, presenters provided an overview and demonstration of the Direct Contracting application portal and answered questions about the portal from the audience.
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Healthcare Reform Proving To Be A Calendar Challenge
Healthcare reform is a significant administrative, clinical, financial and technical undertaking. As the nation moves forward to implement the mandates, the critical resource of time is proving harder to find and pay for. As 2013 comes to an end, the changes expected for 2014 will become more apparent and as we move through the year into 2015, more changes and challenges can be expected.
www.healthcaremedicalpharmaceuticaldirectory.com
John G. Baresky
https://www.linkedin.com/in/johngbaresky
#baresky
The CARES Act: A Simple Summary for InvestorsSusan Langdon
Sweeping legislation to respond to COVID-19 pandemic was cleared by Congress and signed into law on March 27, 2020. The Coronavirus Aid, Relief, and Economic Security Act (“the CARES Act”) authorizes more than $2 trillion to battle COVID-19 and its economic effects. The law is wide-ranging from support to the health care system’s fight against the coronavirus, as well as direct payments to individuals, expanded unemployment insurance, loans to small and large businesses, and support for state and local governments.
This document provides an overview on retirement investor’s relief in the government’s stimulus bill to help alleviate the financial strains from the coronavirus.
As many of us are working remotely during the COVID19 pandemic, we wanted to share some thoughts and
observations about how the pandemic could impact the
medical and retirement plans that you offer to your
employees.
Congress Gave Hospitals and Providers $100B in the Coronavirus Stimulus Packa...Health Catalyst
The COVID-19 pandemic has caused immense financial strain on healthcare systems across the nation. As a result, Congress passed a $3 trillion stimulus package that includes $100 billion for hospitals and other healthcare providers. While this relief for healthcare organizations is much needed, it can also add confusion. What can organizations use these stimulus funds for? What are the risks and compliance requirements?
Bobbi Brown, Senior Vice President of Professional Services, and Dan Orenstein, General Counsel at Health Catalyst, discuss answers to these questions and more. With over thirty years of experience in healthcare financial planning and analysis, Bobbi shares her unique perspective on the stimulus package and how providers can use these funds in their recovery planning. Dan has over two decades of legal experience in healthcare and discusses the specifics of compliance requirements.
In this webinar, Bobbi and Dan address the following:
-Explain significant sections of the four laws passed, including the CARES Act.
-Review program details of the Provider Relief Fund.
-Explore the use of the funds and compliance with terms and conditions.
-Discuss policy changes to better prepare for healthcare emergencies.
This episode continues our COVID-19 COVID-19 Insights Webinar discussing CMS changes, available grants and loans, existing opportunities in telehealth, and more state openings for elective surgeries.
Similar to COVID-19 Update: Understanding the Provider Relief Fund for Dental Providers (20)
C-Suite Snacks Webinar Series: Modern Decision SupportCitrin Cooperman
The role of finance continues to evolve in response to the ever-changing business environment. In order to keep your business agile, it is important to make sure that you're fully benefiting from a best-in-class FP&A function.
During this C-Suite Snacks webinar, Dominic DiBernardo, Partner and Corporate Performance Management Practice Leader, discusses what modern decision support looks like and the ingredients for a great financial planning and analysis (FP&A) function.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
C-Suite Snacks Webinar Series: Building an Advisory BoardCitrin Cooperman
Many private businesses evolve to the point where adding an advisory board can be a significant resource for the owners and senior leadership team, as they accelerate growth and profitability in their companies.
During this C-Suite Snacks webinar, Mark Dailey, a partner at Newport, LLC and seasoned advisory board expert, discusses when you should evaluate building a board, the leading practices and board structures you should consider, and the responsibilities that come with running your board.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
C-Suite Snacks Webinar Series: Prepping Your Company's Financials for SaleCitrin Cooperman
The business acquisitions market is booming and it’s a seller’s market out there! What can you do NOW to make sure that your business is ready?
Join us at our upcoming C-Suite Snacks webinar as Peter Colgan, Transaction Advisory Services Practice manager, discusses what business leaders find most challenging about preparing their financials for sale and how to efficiently conquer those challenges through the lens of a sell-side financial due diligence.
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
Preparing for the new lease accounting standard can seem like a daunting task. In this webinar, we reviewed how you can handle and prepare to navigate your business through the new lease accounting standard in 2022.
Lease Accounting: Preparing Your Business for 2022Citrin Cooperman
Making a smooth transition to the new lease accounting standards and putting new practices in place for the future is a top priority for any business as they plan for 2022. During this webinar session, we reviewed how you can handle and prepare to navigate your business through the new lease accounting standards.
Topics included:
- What private companies should think about for 2022
- How the lease accounting standards can impact your financial
statements, financial covenants, and taxes
- Identifying opportunities for your business due to the new lease
accounting standards
High Net Worth Webinar Series - Tax Planning and Update for 2022Citrin Cooperman
As 2021 comes to an end, business owners and individuals are seeking opportunities to maximize their savings through year-end tax planning. This webinar session will help you navigate the many complexities, obstacles, and impending tax landscape changes that the 2021 tax year brings to the table and what 2022 has in store.
C-Suite Snacks Webinar Series: The Talent Wars - Can Benefits Be Your Secret ...Citrin Cooperman
In today’s candidate-driven job market, offering a competitive benefits package can significantly improve your company’s success in both attracting and retaining talent. In this webinar session, Shaun Gagnon, president and managing partner of Cambridge Insurance Advisors, shares his insights on maximizing your employee benefits to attract employees and combat the talent shortage.
Topics included:
• Trends in open enrollment and wellness fairs
• Popular and practical benefits
• The war on talent
• Cost increases and how to deal with them
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
High Net Worth Webinar Series - The Business of Digital Assets & BlockchainCitrin Cooperman
The recent rise of Bitcoin and digital assets has created significant new opportunities and challenges for investors. This emerging asset class is transforming both the technology and finance industries. In this session, you will learn about Bitcoin, its progeny, the emerging use cases for digital assets, and how investors are getting involved.
Showtime for Shuttered Venue Operators Grant (SVOG) RecipientsCitrin Cooperman
We discuss the ever-changing guidance around the conditions attached to the distribution of these funds and the specific requirements your organization needs to execute.
C-Suite Snacks Webinar Series: A Year Like No Other - Manufacturing and Distr...Citrin Cooperman
Our second annual Manufacturing and Distribution Pulse Survey Report explores the impact of the pandemic on the industry, and how businesses have pivoted to survive, including managing new product offerings, technology implementation, and supply chain disruptions.
During this webinar session, we discussed how 200 leaders of M&D companies, ranging from $20 million to over $1 billion in revenue, responded to our survey.
Topics included:
• How COVID-19 has accelerated the 4th Industrial Revolution
• Product sourcing changes
• Business pivots and what made them successful
Manufacturing & Distribution Update: The Economic Impact on the IndustryCitrin Cooperman
This presentation focused on what the future is likely to bring to manufacturers and distributors as the nation attempts to claw its way back from the worst of the COVID-19 crisis.
C-Suite Snacks Webinar Series: What's Your IP Worth? Discovering the Value of...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
Every day brings news of a new music catalog sale, strategic piece of intellectual property purchased by a large company or private equity firm, or major transaction of a patent-driven business.
During this C-Suite Snacks webinar session, we discussed which intangible assets and intellectual property are commanding the highest prices and what is behind the value of these assets. Key takeaways included:
- An overview of what drives IP value
- COVID-19 impacts on IP value
- Current IP value trends
C-Suite Snacks Webinar Series: Best-In-Class Finance and Accounting: Should Y...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
During this C-Suite Snacks webinar session, Jason Slivka, executive vice president of strategic initiatives, and Steve Ronan, principal and leader of our Business Process Outsourcing Practice, discussed how outsourcing your accounting function drives profitability and business value. They covered:
- Cleaning up historical books and records
- Combining in-house staff and outsourced capabilities
to get best-in-class expertise across your accounting
function
- How better forecasting and financial analysis drives
better management decisions
- Best practices for accounting technology
- Trends in middle-market accounting operations
C-Suite Snacks Webinar Series: Not Sold on Selling Your Business? Why Now is ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The recently proposed tax provisions in the Biden Administration’s American Families Plan should provide substantial incentives for business owners to discuss the creation of an Employee Stock Ownership Plan (ESOP).
During this C-Suite Snacks webinar session, Howard Klein and Heather Oboda covered more about ESOPs, including:
- An overview of what an ESOP is including financial and non-financial benefits
- The common misconceptions about ESOPs
- How the current tax proposals make an ESOP more attractive
MasterSnacks: Cybersecurity - Playing Offense: A Proactive Approach to Cybers...Citrin Cooperman
Sign up for our weekly MasterSnacks courses here: https://www.citrincooperman.com/infocus/mastersnacks
MasterSnacks, our C-Suite Snacks spin-off, brings you a series of topic-specific courses, using our snack-sized sessions to go in depth on content important to you. Join MasterSnacks live every Wednesday at noon for live exclusive sessions.
In today's world, a cyber attack happens every 39 seconds on average. For every doom and gloom story we can tell, there are also instances where another organization’s proactive defense has helped to avoid a cyber attack.
During our final MasterSnacks: Cybersecurity session, we discussed strategies your company can implement to move your IT environment from reactive to proactive. We also shared examples of current clients whose proactive positions have had a real impact in thwarting hackers' attempts at infiltrating their organizations. We covered:
- Case studies on companies that have successfully staved off cyber attacks
- Proactive strategies for protecting your infrastructure
- Automated tools to facilitate more timely evaluation and monitoring
MasterSnacks: Cybersecurity - Disaster Recovery: Hoping for the Best but Plan...Citrin Cooperman
Sign up for our weekly MasterSnacks courses here: https://www.citrincooperman.com/infocus/mastersnacks
MasterSnacks, our C-Suite Snacks spin-off, brings you a series of topic-specific courses, using our snack-sized sessions to go in depth on content important to you. Join MasterSnacks live every Wednesday at noon for live exclusive sessions.
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2. 2
Contents
Important Deadlines:
• Application for Medicaid/CHIP Provider Relief Funds – July 20
• Application for Dental Provider Relief Funds – July 24
• Provider Relief Fund Overview
• Managing Provider Relief Funds
• Eligibility
• Fund Usage & Risk Management
• Tracking, Documentation, and Reporting
• Additional Considerations
• Tax & Audit Considerations
• Transactions
• Other
3. 3
What is the Provider Relief Fund?
The Provider Relief Fund was
created through the CARES Act to
provide much-needed financial
assistance to healthcare providers
in order to support them in
responding to the COVID-19
public health emergency.
These funds are to be used to
prevent, prepare for, and respond
to coronavirus. In addition, these
funds shall only reimburse
providers for healthcare-related
expenses and lost revenues
attributable to coronavirus.
These funds are not considered a
loan, however, providers may
face recoupment if they cannot
substantiate that their lost
revenues and increased expenses
attributable to coronavirus are
equal to or greater than the
amount of Provider Relief Funding
they received. Additionally,
providers must comply with strict
rules around how the funds can
be spent.
We expect these funds to be available for use until the end of the public health emergency.
At that point, we expect any unused funds will need to be returned to HHS.
4. 4
Provider Relief Fund Overview
General Allocation Initial Distribution:
$30 billion Tranche
HHS has announced several targeted allocations in addition to the creation of the Uninsured Relief Fund. HHS has also indicated additional
targeted allocations will be announced in the future
General Allocation Second Distribution:
$20 billion Tranche
$4.9 billion to Skilled Nursing Facilities and $500 million to Indian Health Services
$175BProviderReliefFundAppropriation
$22 billion to COVID-19 High Impact Areas and $11 billion to Rural & Small Metropolitan Area Providers
General Allocation
Targeted Allocation
Unspecified amount for payment of claims for uninsured COVID-19 patients
Future Allocations
Unspecified Amount
$15 billion to Medicaid/CHIP and Dental Providers and $13 billion to Safety Net Hospitals
5. 5
Dental Provider Targeted Allocation
HHS plans to distribute payments to eligible dental providers who apply by July 24. Payments will be based upon 2% of (revenues * percent
of revenues from patient care) for most recent tax filing, as reported by the applicant.
To apply, dental providers must meet ALL of the following eligibility criteria:
1. Must not have received payment from the initial $50 billion Medicare-focused General Distribution; and
2. Must not have received payment from the $15 billion Medicaid and CHIP Distribution; and
3. Must have either (i) filed a federal income tax return for fiscal years 2017, 2018 or 2019 or (ii) be an entity exempt from the
requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return.
(e.g. a stateowned hospital or healthcare clinic); and
4. Must have provided patient dental care after January 31, 2020; and
5. Must not have permanently ceased providing patient dental care directly, or indirectly through included subsidiaries; and
6. If the applicant is an individual, have gross receipts or sales from providing patient dental care reported on Form 1040, Schedule C,
Line 1, excluding income reported on a W-2 as a (statutory) employee.
6. 6
Dental Provider Application Criteria
Dental providers must apply through the Enhanced Provider Relief Fund Payment Portal. It appears that the application requirements for
dental providers are consistent with those for Medicaid/CHIP providers.
Before applying, providers will need to gather the following documentation
1. The applicant’s most recent federal income tax return for 2017, 2018 or 2019 or a written statement explaining why the applicant
is exempt from filing a federal income tax return, (e.g., a state-owned hospital or healthcare clinic).
2. The applicant’s Employer’s Quarterly Federal Tax Return on IRS Form 941 for Q1 2020,
3. Employer's Annual Federal Unemployment (FUTA) Tax Return on IRS Form 940, or a statement explaining why the applicant is not
required to submit either form (e.g. no employees).
4. The applicant’s FTE Worksheet (provided by HHS).
5. If required, the applicant’s Gross Revenue Worksheet (provided by HHS).
In addition to the documentation above, providers will need to provide the following:
• Lost revenue calculation: Calculation of lost revenues due to COVID-19 for March and April 2020
• Increased Expenses: Calculation of increased expenses for March and April 2020
• Payor mix information: Percentage of gross revenues by payor
• Additional COVID-19 Funding: Monies received from other sources, such as the SBA and FEMA
8. 8
Managing Provider Relief Funds
1 Eligibility: Reviewing Terms and Conditions, Certifying Eligibility, and Documenting Fund Receipt
2 Risk Management: Crafting Internal Controls and Determining Allowability of Fund Usage
3 Cost Accounting: Establishing Appropriate Accounting Procedures to Track Funds & Usage
4 Deployment & Documentation: Allocating Funds to Specific Uses and Documenting Use
5 Reporting: Standing Up and Testing Reporting Capabilities
9. 9
General Allocation: Key Eligibility Terms
Category Terms & Conditions Considerations
Acceptance of Terms
and Conditions
Terms and Conditions apply directly to the recipient of the payment. By accepting the terms
and conditions, they attest to (a) being eligible for the funds and (b) agree to adhere to the
terms and conditions for spending the money
If providers received a payment from the Provider Relief Fund under the CARES Act, and
retain that payment for at least 90 days without contacting HHS regarding remittance of
those funds, they are deemed to have accepted the Terms and Conditions.
Generally, most providers who received funding were eligible to receive
it, however, providers must carefully review these terms as some
distributions were made to ineligible providers.
Medicare Standing
Certifications
Recipient billed Medicare in 2019
Recipient is not currently terminated from Medicare participation or precluded from
receiving payment through Medicare Advantage or Part D
Recipient is not currently excluded from participation in Medicare, Medicaid, and other
federal health care programs
Recipient does not currently have Medicare billing privileges revoked
The second tranche of funding, guidance for which was announced April
22, partially targets providers who receive a smaller share of their
reimbursement from Medicare.
Eligibility
Certifications
Recipient certifies that it provides, or provided after January 31,2020, diagnoses, testing, or
care for individuals with possible or actual cases of COVID-19
If providers ceased operation as a result of the COVID-19 pandemic, they are still eligible to
receive funds so long as they provided diagnoses, testing, or care for individuals with possible
or actual cases of COVID-19.
Care does not have to be specific to treating COVID-19.
HHS broadly views every patient as a possible case of COVID-19
The provisions here for general eligibility are extremely broad. Based on
this guidance from HHS, most providers who received funds through
the initial distribution is likely to eligible to keep it for application to
eligible expenses and losses. It is critical to bear in mind, however, that
the breadth of these provisions, particularly the consideration of any
patient as a potential COVID-19 patient and the allowance that care
does not need to be specific to COVID-19, has far-reaching implications
for the other terms and conditions.
Use of Funds
Payment will only be used to prevent, prepare for, and respond to coronavirus AND payment
shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are
attributable to coronavirus
Payment will not be used to reimburse expenses or losses that have been reimbursed for
other sources or that other sources are obligated to reimburse
See next slide
While these eligibility terms are for the General Allocation, the terms are similar among the different distributions. Organizations must,
however, carefully review the terms and conditions for each distribution they receive and attest to those terms and conditions.
10. 10
Eligibility to Retain Funds versus
Eligible Fund Use
A critical issue for those managing Provider Relief Funds is the subtle issue of a provider’s eligibility requirements to retain the funds versus the
eligible uses of the funds. Said more simply, just because a provider is eligible to keep the money does not mean the money can be spent in
whatever manner the provider sees fit. Providers must certify that the funds will only be used to prevent, prepare for, or respond to coronavirus
AND that the payment shall reimburse the recipient only for healthcare-related expenses or lost revenues attributable to coronavirus.
Any revenue that a provider lost due to coronavirus is eligible, including losses
associated with lower visit volume, cancelled elective procedures, or increased
uncompensated care.
Providers can use Provider Relief Fund payments to cover any cost that lost revenue
otherwise would have covered, so long as that cost prevents, prepares for, or
responds to coronavirus and it is not reimbursed (or obligated to be reimbursed) by
another source.
These costs DO NOT need to be specific to providing care for possible or actual
coronavirus patients, however, the lost revenue covered by the Provider Relief Fund
must have been lost due to coronavirus.
HHS is encouraging providers to use these funds to respond to the public health
emergency by maintaining healthcare delivery capacity. Eligible uses include:
Employee or contractor payroll
Employee health insurance
Rent or mortgage payments
Equipment lease payments
Electronic health record licensing fees
Lost Revenue Attributable to Coronavirus
Healthcare-related expenses include a range of items and services purchased to prevent,
prepare for, or respond to coronavirus.
Providers can use these funds to cover eligible costs attributable to coronavirus that were
incurred prior to the date the provider received the Provider Relief Fund payment. HHS
notes, however, that it is unlikely that any eligible costs would have been incurred prior to
January 1, 2020.
Eligible costs include:
Supplies used to provide healthcare services to possible or actual COVID-19 patients
Equipment used to provide healthcare services for possible or actual COVID-19
patients
Workforce training
Developing and staffing emergency operations centers
Reporting COVID-19 test results to federal, state, or local governments
Building or constructing temporary structures to expand capacity for COVID-19
patient care or provide healthcare services to non-COVID-19 patients in a separate
area from where COVID-19 patients are being treated
Acquiring additional resources, including facilities, equipment, supplies, healthcare
practices, staffing, and technology to expand or preserve care delivery
Healthcare-Related Expenses Attributable to Coronavirus
Note: HHS views any patient as a possible coronavirus patient
11. 11
Evaluating Risk in Deploying
Provider Relief Funds
Risk Level Category Description Examples
Low
Risk
Healthcare-
Related Expenses
Expenses incurred at
higher levels, due to
either increased
purchase volume or
increased costs
Expenses that clearly help to prevent, prepare for, or respond to COVID-19
• Additional PPE & PPE purchased at higher rates
• Extra cleaning/sanitizing services
• Modifications to physical plant to improve infection control (e.g., sneeze guards, converting semi-private rooms to private)
• Computers purchased to enable non-clinical staff to work remotely
• Technology purchased to enable telehealth
• Additional workforce training, staffing & unplanned overtime
Lost Revenue
Revenue losses such
that monthly expenses
exceed monthly
revenues
Expenses that must be covered to maintain healthcare delivery capacity, which normally would have been covered by revenue:
• Employee Payroll
• Rent and Mortgage Expenses
• Equipment Leases
• Electronic Health Record Licensing Fees
Medium
Risk
Healthcare-
Related Expenses
Routine expenses
incurred at normal
levels
HHS issued guidance that also provides for the following:
• Supplies used to provide healthcare services for possible or actual COVID-19 patients
• Equipment used to provide healthcare services for possible or actual COVID-19 patients
Because HHS views every patient as a “possible” COVID-19 patient, it is possible more routine expenses would be permissible
Higher
Risk
Healthcare-
Related Expenses
Expenses with only a
tenuous tie to COVID-
19 preparation,
prevention, and
response
Because HHS is interpreting “healthcare-related expenses attributable to coronavirus” as a broad term, it is unclear how flexible
HHS will be in its interpretation. Costs such as the following may be permissible, but we would consider these higher risk:
• Funding on-going plant expansion, such as building a new cancer center
• Routine capex, such as roof repair or boiler replacement
• Upgrading existing technology, such as upgraded software licenses
Lost Revenue
Revenue losses such
that monthly expenses
DO NOT exceed
monthly revenues
This category seems to be one of the riskiest, due to the lack of clarity from HHS. If an organization is still able to cover its costs,
despite diminished top-line revenue, use of Provider Relief Funds to cover operating expenses would effectively reimburse
providers for lost profitability. Usage under this circumstance may violate the term “…Payment shall reimburse the Recipient only
for…lost revenues that are attributable to coronavirus.”
12. 12
Documentation Recommendations
Category Types of Substantiating Documents Purpose
Provider Relief Fund
Summary
Bank statements identifying each award in the entity’s account
Documentation of qualification for each distribution received
Tax returns for 2017, 2018, and 2019
Proof of patient care provided as of January 31, 2020
Recipients will need to be able to report the amount of money received from HHS in
addition to identifying it its accounts all of the federal awards received and expended.
Additionally, we recommend providers maintain documentation of its qualification for each
Provider Relief Fund distribution received (e.g., documentation of COVID-19 admissions for
the High-Impact Area Hospital distribution)
Other Funding &
Reimbursement Sources
Documentation of other funding awards and the fund usage
Provider Relief funds cannot be used to cover any expense or loss that other sources have
reimbursed or are obligated to reimburse
Loss of Revenue
Documentation
2019 Financial Statements (audited, if possible)
2019 Tax Return
2019 Volume Metrics
2020 Internal Financial Statements, beginning in March 2020
2020 Bad Debt estimation, beginning in March 2020
2020 Volume Metrics, beginning in March 2020
It appears that providers will need to be able to substantiate that their lost revenue and/or
increased healthcare-related expenses attributable to coronavirus met or exceeded the
amount of Provider Relief funding they received.
Additionally, pending more specific guidance from HHS, providers should track their bad
debt estimation. Because Provider Relief funds cannot be used to cover any loss or expense
another source is obligated to reimburse, it is not clear whether bad debt can be counted as
lost revenue.
Healthcare-related Expenses
Documentation
Receipt-level detail for all extraordinary expenses attributable to
COVID-19 (i.e., healthcare-related clinical and non-clinical expenses
that would not have been incurred without COVID-19)
Receipt-level detail for all increased ordinary healthcare-related
expenses (e.g., PPE purchased at higher-than-normal costs;
increased volumes of PPE purchased)
2020 line-item budget for healthcare-related expenses
This detail will be required both to substantiate that the Provider Relief funds received were
less than lost revenue/increased healthcare-related expenses incurred as well as to
substantiate the use of the funds to cover any of these costs. Furthermore, the terms and
conditions specify that providers will need to be prepared to provide a comparison of
expenditures to budget amounts.
Costs Normally Covered by
Lost Revenue
Along with documentation substantiating lost revenues:
Receipt-level detail for any healthcare-related expense that
normally would have been covered by lost revenue, which allows
providers to maintain their healthcare delivery capacity (e.g.,
payroll, rent, equipment leases, electronic health record)
Here, guidance remains unclear as to whether providers can cover costs with Provider Relief
funds if their revenue, while diminished, still covers their expense base. At this point, a more
conservative approach appears to be to only use Provider Relief funds for costs when there
is a gap between expenses and revenue. A more aggressive approach would be to calculate
the incurred revenue losses and cover costs up to that level.
Written Controls
Written procedures to implement internal controls, in compliance
with Title 45, Section 75.303
Written procedures for determining the allowability of costs
Providers will need to provide evidence of proper internal controls for the management of
federal funds.
13. 13
Additional Documentation for
Dental Provider Allocation
Types of Substantiating Documents Notes
Bank statements that substantiate no monies from the General Allocation
or Medicaid/CHIP distribution were deposited
Tax returns for 2017, 2018, and 2019
Proof of patient care after January 31, 2020
Proof provider did not permanently cease providing patient care
Providers should maintain deidentified records of patient care to
substantiate that patient care was provided after January 31, 2020 and did
not permanently cease.
14. 14
Provider Relief Fund Oversight
Category Key Terms and Conditions Considerations
Reporting
Expectations
Recipient shall submit reports as the Secretary determines are needed to ensure compliance with conditions…such
reports shall be in such form, with such content, as specified by the Secretary in future program instructions directed
to all Recipients.
This language makes it clear that there will likely be additional
reporting requirements for ALL Provider Relief Fund Recipients.
As such, providers need to ensure careful tracking of all funds
received and how they have been used.
Reporting
Requirements
(add’l detail on
next slide)
No later than 10 days after the end of each calendar quarter, recipients that received more than $150k total in funds
under the CARES Act or any other Act primarily making appropriations for the coronavirus response and related
activities, shall submit a report containing information like the amount of funds received and funds
obligated/expended.
Careful tracking of all funding secured through the various acts
enacted to address the COVID-19 crisis and its use will be
critical. This tracking will need to include funding from PPP, the
Main Street Lending Program, Medicare Advance Payments, and
others.
Record Keeping
(add’l detail on
next slide)
The recipient shall maintain appropriate records and cost documentation, including documentation required by Section
75.302 of Title 45 of the Code of Federal Regulations, including information such as financial results of each award,
identification of the award in its accounts, and written controls, among other requirements.
Here again, careful record keeping will be critical to ensure
compliance and prepare for any potential future audits.
Additionally, documentation of internal controls will need to be
developed if not already in place.
Other Conditions
In addition to the terms outlined above, general provisions of FY2020 consolidated appropriations also apply, including
prohibition of the use of funds for compensating individuals above $197,300, lobbying, abortions, gun control
advocacy, and needle exchange programs, among others.
Recipients should be sure to review all terms and conditions
included in this section.
The CARES Act obligates the OIG to perform both interim and final audits on distributed funds and to report its findings to the Senate
and House Appropriations Committees over the next three years.
Below, we have provided a high-level outline of the reporting requirements set forth in the Terms and Conditions. These
requirements are generally the same across all distributions. HHS issued guidance this week, however, that clarifies that
providers will not need to provide separate quarterly reporting at this stage, though providers should expect to be
required to provide reporting in the future that substantiates their use of the funding.
15. 15
Provider Relief Fund Oversight:
Additional Details
Category Terms & Conditions
Reporting
Requirements
Recipient will submit reports HHS deems are needed to ensure compliance with conditions imposed on the payment
No later than 10 days after the end of each calendar quarter, recipients that received more than $150k total in funds under the CARES Act, the Coronavirus Preparedness
and Response Supplemental Appropriations Act, the Families First Coronavirus Response Act or any other Act primarily making appropriations for the coronavirus response
and related activities, shall submit a report containing:
o Amount of funds received from HHS
o Amount of funds received that were expended/obligated for each project or activity
o A detailed list of all projects or activities for which large covered funds were expended/obligated, including the name of the project, description, and estimated
number of jobs created/retained by the project, where applicable
o Detailed information on any level of subcontracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees
Record Keeping
The recipient shall maintain appropriate records and cost documentation, including documentation required by Section 75.302 of Title 45 of the Code of Federal
Regulations:
o Identification in its accounts of all federal awards received and expended, including the CFDA title and number, federal award identification number and year, and the
name of the HHS awarding agency
o Accurate, current, and complete disclosure of the financial results of each federal award. If the HHS awarding agency requires reporting on an accrual basis from a
recipient that does not maintain its records on an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may
develop accrual data for its reports on the basis of an analysis of documentation on hand.
o Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to federal
awards, authorizations, obligations, unobligated balances, assets, expenditures, income, and interest and be supported by source documentation
o Effective control over and accountability for all funds, property, and other assets.
o Comparison of expenditures with budget amounts for each federal award
o Written procedures to implement internal controls, per requirements of section 75.303
o Written procedures for determining the allowability of costs
The recipient shall promptly submit copies of such records and cost documentation upon the request of HHS
The recipient agrees to fully cooperate in all audits HHS, the Inspector General, or the Pandemic Response Accountability Committee conducts to ensure compliance with
Terms & Conditions
16. 16
Understanding Risk: False Claims Act
Because distributions from the Provider Relief Fund are payments from the government, the False Claims Act (“FCA”) applies to these funds.
The CARES Act allows the government to pursue FCA action if providers do not comply with the terms and conditions. Providers should work
with legal counsel to understand FCA considerations unique to their practice.
Key Considerations
What is the FCA?
Also known as the “Lincoln Law,” the FCA imposes a liability on anyone who defrauds the
government. Under the FCA, the government can also impose liabilities on anyone who
“knowingly and improperly” conceals an obligation to return money to the government,
known as a “reverse false claim.” Providers may be liable under the FCA if they do not use
Provider Relief Fund monies for eligible uses.
What kind of damages can the
government seek?
Under the FCA, the government can seek treble damages for violations.
How does the FCA apply to the
Provider Relief Fund?
Based on the language in the Terms and Conditions for the Provider Relief Fund, providers
must (a) certify their eligibility, (b) be sure to only use the funds for approved uses, and (c)
ensure sufficient documentation and tracking so as to be able to substantiate their eligibility
and use of funds.
18. 18
The IRS has confirmed
that the Provider Relief
Fund will be
considered taxable
income for non-tax
exempt entities
Tax & Audit Considerations
In considering 2020
audits, Provider Relief
funding may require a
subsequent event
footnote disclosure
The Provider Relief
Fund is excluded from
CFDA single audit
requirements
19. 19
Provide Relief Fund distributions have all been made according to Tax Identification Number (TIN) and many of the distribution
methodologies have used historical performance to allocate funds. The approach of identifying organizations based on TIN and making
distributions based on historical performance has created a complex web of concerns for any entity that has undergone a transaction in
the past two years as well as those currently exploring or undertaking a transaction.
Fund Management in a Transaction
Providers who are contemplating a transaction or who have undergone a transaction since 2018 must be very careful to
ensure they handle their Provider Relief Fund distributions appropriately, to avoid violating the terms and conditions.
Key Considerations
Tie to TIN Owner
Funds are tied to the TIN to which they were distributed. Funds cannot be transferred from one TIN owner to another.
NOTE: Parent entities are permitted to distributed funds to their subsidiaries as they see fit, so long as the subsidiaries
do not file separate tax returns
Risks for Newly Formed
Entities
If a new entity was created for the purposes of a transaction, e.g., a new LLC holding company, buyers will likely be shut
out of existing Provider Relief Fund distributions and, significantly, may also be at risk for missing out of future rounds.
Attesting to Funds versus
Avoiding Recoupment
The evolving guidance has made it clear that the bar for organization to meet eligibility requirements and attest to the
terms and conditions is considerably lower than the bar for organizations to substantiate the appropriate use of the
funds under the terms and conditions and avoid recoupment by HHS.
20. 20
Other Critical Considerations
Balance Billing
Providers who accept these funds are generally prohibited from “balance billing” for all care for
a presumptive or actual case of COVID-19. The application of this term can be complex and will
likely require providers to be able to track billing and receipts at the patient encounter level.
Bankruptcy
These funds shall not be subject to the claims of a provider’s creditors. Providers do, however,
have a limited ability to satisfy a creditor’s claim using these funds, to the extent such claims are
in compliance with eligible uses of the funds.
Other Funding Programs
These funds cannot be used to cover expenses/losses that have been reimbursed by other
sources or that other sources are obligated to reimburse. As such, carefully monitoring the
allocation of other funding sources, including patient and insurance receivables, is critical
21. evolution COVID -19 UPDATE
FOR MORE INFORMATION:
actioninto
Kate Broderick
Manager
kbroderick@citrincooperman.com
419.367.6334
Aaron Cohen
Principal, Healthcare Co-Practice Leader
acohen@citrincooperman.com
301.654.9000
John Bryan, CPA
Partner, Healthcare Co-Practice Leader
jbryan@citrincooperman.com
914.949.2900
Michael Criscione, CPA
Partner, Healthcare Co-Practice Leader
mcriscione@citrincooperman.com
401.421.4800
Gary Bagoff, CPA
Partner, Dental Practice Leader
gbagoff@citrincooperman.com
973.218.0500