We can't say this enough: If you received, or think you should receive, pandemic-related provider relief money from HHS under the Cares Act, become a frequent visitor to the program's Frequently Asked Questions page.
Bookmark the page. Check in regularly. Read thoroughly.
Why? HHS is developing and refining policies on the fly — clarifying gray areas, adding requirements, shifting positions on earlier decisions, you name it — and the only way to make sure you're complying (and using relief funds to the fullest extent possible) is by keeping up with all the changes.
To illustrate what we mean, here are a few changes made over just the past few days.
There's a minimum amount of relief money HHS will provide. HHS clarified that the Provider Relief Fund “does not issue individual General and Targeted Distributions payments that are less than $100.”
Hiring enticements could be considered payable expenses. HHS announced that expenses incurred “to secure and maintain adequate personnel, such as offering hiring bonuses and retention payments, child care, transportation, and temporary housing, are deemed to be COVID-19-related expenses if the activity generating the expense was newly incurred after the declaration of the Public Health Emergency and the expenses were necessary to secure and maintain adequate personnel.”
Relief funds can be used to pay taxes (on relief funds). According to the updated FAQs, HHS “considers taxes imposed on Provider Relief Fund payments to be ‘healthcare related expenses attributable to coronavirus’ that are reimbursable with Provider Relief Fund money, except for Nursing Home Infection Control Distribution payments.”
Vaccine distribution costs can be paid for with relief funds. “Provider Relief Fund payments may be used to support expenses associated with distribution of a COVID-19 vaccine licensed or approved by the Food and Drug Administration that have not been reimbursed from other sources or that other sources are not obligated to reimburse,” writes HHS, adding that those expenditures “may include using funds to purchase additional refrigerators, personnel costs to provide vaccinations, and transportation costs not otherwise reimbursed.”
HHS clarifies that if another source — which could include Medicare, Medicaid, and CHIP — reimburses for vaccine expenses, but if the amount doesn't cover the full cost of administering vaccines, then "Provider Relief Funds may be used to cover the remaining associated costs."