COVID-19 Documentation Essentials for Healthcare Providers

Many healthcare providers have gladly welcomed the variety of economic relief programs designed to soften the financial blow during the coronavirus outbreak. As cash flow management concerns, changes in patient care, and operational issues take center stage, documentation of these funds and how they are used can easily be neglected.

However, some economic relief programs have a reporting or compliance requirement. Documenting information now will help ensure you remain fully compliant and avoid any surprises in the future. If you haven’t already, start a folder for all coronavirus-related loans, funding, and documents. Here is an overview of what you should be tracking and documenting.

Funding Sources

Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Payments

Once you receive payment, you will need to complete the attestation form and review the terms and conditions. By law, relief payment recipients have to provide quarterly reports if they received over $150,000 in funds related to the coronavirus response. These reports are submitted to the Secretary of the Department of Health and Human Services (HHS) and to the Pandemic Response Accountability Committee, and the first of these reports is due by July 10. The reports should contain the following:

• Amounts received from each program (by Taxpayer Identification Number, if there are multiple)
• Amounts expended or obligated by project or activity
• A listing of projects or activities that benefited from these funds, including the purpose, jobs created (or sustained), and any subcontracting that was performed

Providers should also record the date they received the payment(s) from HHS. More information on the program requirements is available on HHS’s website.

Paycheck Protection Program (PPP) Loans

The hallmark of the PPP loans is the potential for loan forgiveness. However, the responsibility is on the loan recipient to earn 100% forgiveness, which makes documentation critical. There are still many unanswered questions about how forgiveness will be calculated, but we do know that the forgiven amount can be reduced if businesses reduce headcount or wages paid to employees. There are a number of considerations when calculating loan forgiveness, and more detailed guidance is still forthcoming.

U.S. Small Business Administration (SBA) Economic Injury Disaster Loan (EIDL) Program

Since loans issued via the EIDL program are not forgivable, providers will not need to document the same information as they would for PPP loans. However, providers who received EIDL funding should document the use of the proceeds in a simple spreadsheet for tracking purposes and should maintain supporting documentation in a separate folder for backup in the event the SBA inquires.

The Centers for Medicare and Medicaid Services (CMS) Accelerated and Advance Payment Program

Recoupment of the accelerated and advance payments will begin automatically 120 days from receipt, barring unusual circumstances. That means that each claim submitted after 120 days will reduce the outstanding accelerated/advance payment balance and that no new payment will be received. The repayment process is automatic, which means no additional forms are required. Providers should prepare or update their cash flow projections to ensure adequate liquidity once the Medicare recoupment begins.

The process and timeline are different for hospitals. At the end of the one-year period, Medicare Administrative Contractors (MACs) will perform manual checks to determine the remaining balance, which will be collected by direct payment.

Please note that as of April 26 CMS has suspended the Advance Payment Program for Medicare Part B participants.

Other Funding

Providers who sought other sources of cash due to the pandemic, such as a line of credit or using personal savings, should make sure to record the amount of the alternative funds and when they went into the business.

Operations

Knowing the impact of COVID-19 upon your practice’s operations will help you complete the requisite funding reports mentioned previously and will help prepare you for the future, whether it is addressing physician compensation, budgeting, or forecasting. Many providers may have already calculated the COVID-19 operational impact when deciding whether to apply for loans, but if you haven’t already, you should start tracking the impact of COVID-19 related to the following:

• COVID-19 care: If your group provided direct care to confirmed or suspected COVID-19 patients, make sure you are coding these encounters correctly. Consider developing a report in your billing or electronic medical record (EMR) system based on these codes.
• Revenue: Even if your practice did not directly see COVID-19 patients, volumes and revenues were likely impacted. From your billing or EMR system, determine collections and receipts for each month of 2019, and use it as a baseline for determining the COVID-19 impact in 2020.
• Personal protective equipment (PPE) and supplies: If you had to purchase additional supplies such as PPE, consider running expense reports from your general ledger by month. Compare those amounts against the same period of the prior year.
• Physician compensation: Document when the COVID-19 impact materially began and ended, specific to each individual physician. Having a document trail in a physician’s contracting file will provide compliance support for addressing physician compensation issues in light of COVID-19.

By diligently documenting and preparing now, providers will be better prepared for the second half of the year and for the future. Larger organizations may consider implementing a more formalized compliance program.

If you need help navigating these compliance requirements or strategizing how you can best position your organization, our team stands ready to help. Please reach out to your KSM advisor or complete this form.

Visit the KSM COVID-19 Resource Center