If your healthcare practice or organization received and kept COVID-19 federal relief funds totaling more than $150,000, you are required to submit a report to HHS at the end of each calendar quarter. The report, as previously outlined by Grassi Healthcare Advisors, needs to detail how you spent these relief funds.
The $150,000 threshold for reporting includes not only funds from the $30 billion and $20 billion HHS disbursements, but also any other COVID-19 federal relief your organization received. For example, if you received $50,000 in HHS funds and a $120,000 Paycheck Protection Program Loan, the $170,000 amount puts you over the threshold limit for reporting.
Here is the excerpt from the HHS Terms and Conditions, which you agreed to if you accepted the HHS relief payments:
Not later than 10 days after the end of each calendar quarter, any Recipient that is an entity receiving more than $150,000 total in funds under the Coronavirus Aid, Relief, and Economics Security Act (P.L. 116-136), the Coronavirus Preparedness and Response Supplemental Appropriations Act (P.L. 116-123), the Families First Coronavirus Response Act (P.L. 116-127), or any other Act primarily making appropriations for the coronavirus response and related activities, shall submit to the Secretary and the Pandemic Response Accountability Committee a report. This report shall contain: the total amount of funds received from HHS under one of the foregoing enumerated Acts; the amount of funds received that were expended or obligated for reach project or activity; a detailed list of all projects or activities for which large covered funds were expended or obligated, including: the name and description of the project or activity, and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any level of sub-contracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the Director of the Office of Management and Budget.
The Recipient shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR § 75.302 – Financial management and 45 CFR § 75.361 through 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate the reimbursement of costs under this award. The Recipient shall promptly submit copies of such records and cost documentation upon the request of the Secretary, and Recipient agrees to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with these Terms and Conditions.
The first report is due on July 10, 2020. If you have not already, you should put a plan in place immediately for how you will be spending these funds, so that at the end of each quarter you can easily report on expenses related to each of those projects. We are still awaiting guidance on how these reports will be submitted, but the tracking and gathering of information should begin right away.
If you need assistance with planning your spending, compiling your expenses and complying with this new HHS reporting requirement, Grassi Healthcare Advisors is here to help. Please contact Joseph Tomaino, Healthcare Consulting Leader, for more information on our healthcare advisory, emergency loan assistance and compliance services.