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.
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