Provider Relief Fund Distribution Payments May Be Subject To Audit Requirements

In the CARES Act that became law with President Trump's signature on March 27, $100 billion has been set aside for "health care related expenses or lost revenues that are attributable" to the COVID-19 pandemic. Commonly referred to as the "Provider Relief Fund," the stated purpose of this $100 billion fund (which has been supplemented with an additional $75 billion pursuant to the Paycheck Protection Program and Health Care Enhancement Act) is to address the economic harm suffered by healthcare providers that have incurred (or will incur) additional expenses and have lost (or will lose) significant revenue as a result of the pandemic. Payments made from the Provider Relief Fund have been made from either the "General Distribution" or various "Targeted Distributions".  Health care providers that have received (or will receive) payments from either the General Distribution or any of the Targeted Distributions may be subject to certain audit requirements.