During the course of the COVID-19 pandemic, around $178 billion in relief funding was distributed to hospitals and other health care providers through the Provider Relief Fund. Among other requirements, recipients had to attest that, for all care of presumptive or actual COVID-19 patients, the recipient would not seek out-of-pocket payments in excess of what patients would otherwise have had to pay if in-network providers had furnished the care.
HHS recently announced that it will perform a nationwide audit to determine whether hospitals that received relief funds have complied with this requirement for COVID-19 inpatients. HHS will assess the calculation of bills for out-of-network patients admitted for the treatment of COVID-19, and also review documentation for compliance. HHS will also assess procedural controls and monitoring to further ensure compliance. Hospitals and health care providers that have received Provider Relief Fund distributions should prepare for the prospect of a federal audit of their institution’s billing practices.