Public Health and Social Services Emergency Fund
May 14, 2020
So you’ve retained funds provided under the Public Health and Social Services Emergency Fund in the CARES Act. What next?
We’ve compiled a checklist to maintain your compliance with the program’s conditions and reduce the risk of audit issues, government investigations and potential civil liability.
Segregate funding received under the Public Health and Social Services Emergency Fund
Consider maintaining the provider relief funding in a separate bank account than accounts used for non-COVID-19 relief purposes. This will instill discipline in using the funds only for qualified purposes. One of the conditions with funding includes the requirement to maintain records and cost documentation, which is easier when the funding is kept separate. And it will make responding to any subsequent audit, if one occurs, that much less painful.
Foley Hoag has formed a firm-wide, multi-disciplinary task force dedicated to client matters related to the novel coronavirus (COVID-19). For more guidance on your COVID-19 issues, visit our Resource Portal or contact your Foley Hoag attorney.