Don’t Let Today’s Relief be Tomorrow’s Grief
The Department of Health and Human Services (HHS) has distributed billions of dollars under the Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Fund (PRF) and issued over 100 blanket waivers and flexibilities to assist providers in responding to COVID-19 during the public health emergency. The rules around the PRFs and waivers are clarified and modified regularly, making it difficult for providers to stay in compliance with federal requirements.

The Office of Inspector General (OIG) updated its 2020 Work Plan with COVID-19 related audits, evaluations, and inspections. Some of the objectives are to:

  • Determine whether providers complied with certain federal requirements for:

  • Reporting and expending PRF
  • Reimbursement received through Health Resources & Services Administration’s (HRSA's) COVID-19 Uninsured Program
  • Medicare payments to hospitals for COVID-19 inpatient discharges
  • Infection prevention and control and emergency preparedness in nursing homes and home health agencies

  • Examine Medicare claims data for laboratory testing to identify trends in the use of add-on tests such as respiratory pathogen panel, allergy, and genetic testing, and identify patterns of billing by laboratories that may indicate fraud and abuse.
To avoid grief down the road, your compliance department should maintain documentation of the use of all funds and waivers and review all OIG COVID-19 Work Plan items to identify known risk areas that may affect your organization. Identified risk areas applicable to your organization should be incorporated into your auditing and monitoring efforts to evaluate your compliance with the regulations and guidelines. For more details, contact your ACT client service representative, or email us at