Provider Relief Fund compliance will require an extensive and far-reaching program, say Anna Stevens, CPA, CHFP, partner-in-charge of healthcare services in the Houston office of Weaver, and Rebecca Goldstein, CPA, an accountant in partner assurance services in the firm’s Austin, TX, office.
Stevens and Goldstein suggest a good compliance program should include these elements:
- Established policies and procedures related to COVID-19 expenditure documentation, retention, and reporting.
- A grant or compliance manager to oversee the expenditures, reporting, and basic grant management cycle from start to finish, including communicating with HHS.
- Thorough backup documentation of all expenditures expected to be reimbursed with Provide Relief Funds.
- Payroll documentation, including timesheets, paystubs, and complete human resource files with positions listed for all individuals paid with grant funds.
- For significant nonpayroll expenditures, use of a procurement checklist showing history of bid solicitation, cost/price analysis, justification for noncompetitive procurement, and documentation that vendors are not suspended or debarred.