Provider Relief Fund Recipients Subject to Green Book Internal Control Requirements – Are You Ready?
As of January 8, 2021, HHS has not released any further guidance on the Provider Relief Fund (PRF) reporting portal scheduled to be available on January 15.
However, in late December, HHS continued to issue other updated FAQs on the PRF. On December 28, 2020, they verified that ALL recipients of PRF funds are subject to 45 CFR 75 - UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS and specifically included 75.303 – Internal Controls. This Section says that recipients are subject to the requirements of the “Green Book,” the Standards for Internal Control in the Federal Government, issued by the Office of the Comptroller General of the United States.
Many providers may not be aware of some of the requirements this imposes. For example, the Green Book includes a section on Documentation Requirements (OV4.08). This specifies that:
- “Management develops and maintains documentation of its internal control system. (paragraph 3.09)
- Management documents in policies the internal control responsibilities of the organization. (paragraph 12.02)
- Management evaluates and documents the results of ongoing monitoring and separate evaluations to identify internal control issues. (paragraph 16.09)
- Management evaluates and documents internal control issues and determines appropriate corrective actions for internal control deficiencies on a timely basis. (paragraph 17.05)
- Management completes and documents corrective actions to remediate internal control deficiencies on a timely basis. (paragraph 17.06)”
Depending on the size of your organization, many of the requirements may be included in your compliance program. However, we believe that all recipients of the PRF should review the Green Book requirements to ensure compliance. The Terms and Conditions Document that providers executed contractually obligates providers to meet these requirements.
Now is the time to complete your filing requirements. Based upon client questions we have received, this is not something that can be put together overnight. Our team is experienced in using the Green Book framework to set effective internal control systems. Our professionals can review your current internal control compliance and help create the necessary policies and procedures required by HHS for filing. Please contact Ron Present at 314.983.1358 or firstname.lastname@example.org or Mark Renken at 636.754.0234 or email@example.com.