* * * * * This post sponsored by Deloitte & Touche, LLP. * * * * *
The ongoing COVID-19 crisis has led to the adoption of a number of health care legislative and regulatory programs to provide financial relief for healthcare organizations. As part of receiving these benefits, healthcare organizations are responsible for ensuring that associated financial and regulatory reporting requirements are met. Over the last month alone there have been multiple updates, clarifications and even suspension of certain financial relief programs, so we need to continuously monitor HHS, CMS, HRSA, FEMA and other agency guidance to understand the requirements, terms and conditions of the programs. This will help healthcare organizations stay informed and maximize COVID-19 financial recovery options.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act – the largest stimulus package in US history – was signed into law on March 27, 2020. This, together with the Paycheck Protection Program and Health Care Enhancement Act, provides a total of $175 billion in emergency relief funding infusion to hospitals and health care providers to provide support for COVID-19 related expense and lost revenue.
Along with the Public Health Emergency funds, there are a variety of other funding sources including Federal Emergency Management (FEMA), Payroll Tax Relief, Federal Communications Commission (FCC) Funding Opportunities and even state and local grants available for hospitals and health care providers to compensate for COVID-19 related costs. However, it is important to understand the eligibility requirements for each program, what an organization can pursue or not based on their structure and tax status and how to avoid “double dipping”, i.e. using the funds to cover expenses otherwise funded through other sources.
From early responses we are seeing to COVID-19 financial recovery, there are some leading practices that organizations should follow to help prepare a focused strategy and roadmap to navigate through the many phases of the CARES Act and other funding – from receipt of funds to preparing for potential future audits. It is important to get organized by aligning on an approach to navigating relief sources, confirm if any insurance policy coverage options exist, and determine which COVID-19 related relief expenditures and costs are reimbursable.
Please be on the lookout for additional webinar sessions as we continue to monitor the healthcare legislative and regulatory programs related to COVID-19 to bring you the latest and most relevant information for your organization.
About the Authors:
Kelly J. Sauders is a Partner at Deloitte & Touche LLP with over 25 years of experience in the health care industry. She specializes in providing regulatory compliance, risk and control-related services.
Heather Hagan is a Senior Manager at Deloitte & Touche LLP with nearly 15 years of experience providing operational improvement, enterprise and strategic risk, and regulatory compliance services to health care organizations.
Phone: +1 215.439.1278
The following employees of Deloitte & Touche LLP were also contributors to this blog and webinar: Dhara Satija, Senior Manager and Minal Singhee, Senior Consultant.