New Terms and Conditions Necessitate Keen Attention to Compliance
As we previously reported, on April 10, 2020, HHS issued an initial disbursement from the Public Health and Social Services Emergency Fund (Relief Fund) that was created in the CARES Act. This initial disbursement of $30 billion was based on eligible recipients’ proportionate share of the total Medicare fee-for-service reimbursements from 2019. While recipients did not have to apply in order to receive these funds, this disbursement was accompanied by Terms and Conditions that imposed strict eligibility and usage requirements. We previously summarized significant aspects of the Terms and Conditions, which implicate compliance risks for recipients of the Relief Funds, in our April 17, 2020 article. Click here to read more.