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AHLA Institute on Medicare and Medicaid Payment Issues

Who CARES how you spent CARES Act funds? The OIG: Be Prepared for CARES Act Audits
Co-Presenters:
Jeffrey S. Cohen, Audit Director, Office of the Inspector General, US Department of Health and Human Services
Joseph Geraci, Husch Blackwell
Julie Sullivan, Greenberg Traurig LLP
Summary/Overview: The Coronavirus Aid, Relief, and Economic Security (CARES) Act allocated tens of billions of dollars for the Provider Relief Fund (PRF) to support health care providers affected by the COVID-19 pandemic. The HHS-OIG has included various CARES Act audit topics to its Work Plan, and providers should ensure their documentation is in order in anticipation of these audits. In this presentation, we will review the ground rules for the various Provider Relief Act funding distributions, and discuss what auditors may expect to see from various providers to determine that the providers complied with the terms and conditions for reporting and expending PRF funds.
  • The Coronavirus Aid, Relief, and Economic Security (CARES) Act allocated tens of billions of dollars for the Provider Relief Fund (PRF) to support health care providers affected by the COVID-19 pandemic. The HHS-OIG has included various CARES Act audit topics to its Work Plan, and providers should ensure their documentation is in order in anticipation of these audits.
  • What are the likely areas of focus for the OIG (and other federal auditors).
  • In light of the often confusing and changing sub-regulatory guidance provided by HHS, what factors will the OIG take into consideration when deciding on penalties.
  • How will the OIG audits differ from a Single Audit?
  • What are best practices for preparing for an audit?