Reingruber Alert: CARES Funds Attestations

5/12/2020 - By Claudia Reingruber, CPA, CHC

New Deadlines for Attestation & Submission of Required Data

General Distribution Attestations are Now Due within 45 Days of Receipt

Round #1 - $30 billion was paid between April 10 - 17, 2020

New Deadline is May 24, 2020 for most providers

Round #2 - Distributions from the $20 billion began 04/24/2020

New Deadline is June 7, 2020 for most providers

Attestation Must Be Supported by Specific Information Including:

"Estimates of Lost Revenues in March and April of 2020"
Tax Return Data

Tax Identification Number (TIN)
TINs for subsidiary organizations without separate tax returns
Copy of most recent tax return filed

Data from CARES Funds Received

Amount of payments received (Tranches 1 and 2)
Relief Fund Payment Transaction Numbers and check numbers

Is Your Estimate of Lost Revenues in March & April 2020 Accurate?

HHS Offers Considerable Latitude with Lost Revenue Estimates

Estimates of lost revenue for March and April of 2020 are required
Examples from HHS of the types of data to consider include the following:

Comparison of year-over-year revenue
Comparison of budgeted revenues to actual revenues
Extrapolation from trends in earlier months

Carefully consider your unique circumstances in formulating estimates

Prepare Now for CARES Act Funds Quarterly Reporting

All providers that received CARES Funds must support their use

Providers that received more than $150,000 will be required to submit quarterly reports, with the first one due 07/10/2020
All providers, regardless of amount received, must maintain documentation on the use of funds and are subject to audit
Even though details for the quarterly reports have not been published, now is the time to prepare!

Providers must have internal accounting mechanisms in place now

Segregate CARES Fund receipts in separate G/L cash account
Provide department heads with expense tracking tools
Document personnel time attributable to COVID-19 tasks
Consider all aspects of COVID-19 efforts after January 31, 2020

HHS plans oversight and enforcement mechanisms to ensure providers:

Comply with relief fund terms and conditions
Document use of funds for increased healthcare-related expenses and lost revenue attributable to COVID-19
Separate expenses and losses from those reimbursed by other sources

HHS and OIG will undertake anti-fraud monitoring and oversight

The Healthcare Division at Saltmarsh can help you:

Establish cost accounting to track compliant use of grant funds
Assist with preparation of lost revenue estimates for March and April 2020
Identify other available COVID-19 relief programs you may have overlooked
Untangle complicated federal rules governing COVID-19 documentation
Help you benefit from available resources to meet ongoing challenges!

QUESTIONS?

If you have questions about your particular circumstances, please contact our team or call (800) 477-7458.

Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult a professional.