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OMB Compliance Supplement Update and FAQs

Your Weekly Provider Relief Fund (PRF) Update

There has a been a flurry of information coming from Washington in the last week surrounding the Provider Relief Fund (PRF).

In addition to the COVID relief bills and other spending bills, HHS continues to release FAQs on the PRF and the Office of Management and Budget (OMB) released their compliance supplement for auditing COVID relief programs.

Weekly Insights

The 2020 OMB Compliance Supplement (the Supplement addendum) was released on December 22. This file gives guidance to those auditing COVID relief programs, including the PRF and Coronavirus Relief Funds (CRF).

The guidance does provide a direct link to the FAQs from HHS on how the funds are to be utilized and continues to promote that “these funds may not be used to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.”

While the compliance supplement doesn’t provide additional specifics on reimbursable costs, it does offer a consistent message as to how PRF reporting will occur.

Key Takeaways
  1. All COVID-related costs may be used in the calculation of COVID expenses. Earlier FAQs frequently mentioned “incremental” costs only were to be included but this language has been dropped from HHS and OMB literature in the past month
  2. COVID costs need to be reduced by all other reimbursed sources. Recurring examples from HHS include other grants, Paycheck Protection Program loans, reimbursement from Commercial Insurance, Medicare, Medicaid, CHIP and FEMA.
  3. More detail is still needed from HHS and OMB but we are consistently seeing language that indicates providers need to accumulate all costs related to preventing, preparing for and responding to COVID-19.

Download a PDF version of this blog post and read through the HHS FAQs here. You can also visit the HHS website, CARES Act Provider Relief Fund: FAQs for more information.

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