Ten of Thirty Selected Nursing Facilities Did Not Comply or May Not Have Complied With Terms and Conditions and Federal Requirements for Expending Provider Relief Fund Payments, A-05-22-00012

Full text

June 2025 | A-05-22-00012

Ten of Thirty Selected Nursing
Facilities Did Not Comply or May
Not Have Complied With Terms and
Conditions and Federal
Requirements for Expending
Provider Relief Fund Payments




                       OIG.HHS.GOV
June 2025 | A-05-22-00012
Ten of Thirty Selected Nursing Facilities Did Not Comply or May Not
Have Complied With Terms and Conditions and Federal Requirements
for Expending Provider Relief Fund Payments
Why OIG Did This Audit
   •   Congress appropriated $178 billion to HHS for the Provider Relief Fund (PRF), which provided
       reimbursement to eligible providers for health care-related expenses or lost revenue attributable to
       COVID-19. HHS was responsible for initial PRF program oversight and policy decisions, and HRSA
       administered the PRF program.
   •   Providers receiving PRF payments were to ensure that the payments were: (1) used to prevent,
       prepare for, or respond to COVID-19; (2) used for health care-related expenses or lost revenues
       attributable to COVID-19; (3) not used to cover expenses or losses reimbursed by other funding
       sources; and (4) not used to pay salaries in excess of a certain threshold or to pay for certain prohibited
       activities.
   •   This audit is part of a series reviewing PRF payments to various provider types. Specifically, this audit
       assessed whether 30 selected nursing facilities expended taxpayer funds in accordance with Federal
       and program requirements.

What OIG Found
   •   Of the 30 selected nursing facilities we reviewed, 8 nursing facilities used $2.3 million in PRF payments
       for unallowable expenditures or lost revenues, and 3 nursing facilities used $333,000 in PRF payments
       for expenditures that may not have been allowable. These nursing facilities (10, including 1 nursing
       facility that had more than 1 deficiency) received a total of $178 million in PRF payments. The
       remaining nursing facilities used PRF payments for allowable expenditures and lost revenues.
   •   These deficiencies occurred because although nursing facilities attested to the PRF terms and
       conditions and HRSA provided continuously updated guidance to PRF recipients, the nursing facilities
       did not always maintain documentation to support reported expenditures, may have misinterpreted
       HRSA’s guidance, made clerical errors, or did not effectively track expenses funded by PRF payments.

What OIG Recommends
We made two recommendations to HRSA, including that it require the selected nursing facilities to return any
unallowable expenditures and lost revenue amounts to the Federal Government or ensure that the nursing
facilities properly account for these expenditures and lost revenues. HRSA concurred with our
recommendations.




                                                  OIG.HHS.GOV
                                                         TABLE OF CONTENTS

INTRODUCTION ............................................................................................................................... 1

           Why We Did This Audit ....................................................................................................... 1

           Objective ............................................................................................................................. 1

           Background ......................................................................................................................... 2
              The Provider Relief Fund............................................................................................... 2
              HHS’s and HRSA’s Oversight of the Provider Relief Fund Program .............................. 3
              Requirements for Nursing Facilities That Received Provider Relief Fund Payments ... 4

           How We Conducted This Audit ........................................................................................... 7

FINDINGS ......................................................................................................................................... 8

           Some Nursing Facilities Used Provider Relief Fund Payments for Unallowable
            Expenditures and Lost Revenues ..................................................................................... 9
              Unallowable Costs......................................................................................................... 9
              Costs Not Adequately Supported ............................................................................... 10
              Unallowable Use of Nursing Home Infection Control Provider Relief Fund
                Payments .................................................................................................................. 11
              Inaccurate Lost Revenue Calculation .......................................................................... 11

           Some Nursing Facilities May Have Used Provider Relief Fund Payments for
            Unallowable Expenditures ............................................................................................ 11

           Causes for Unallowable and Potentially Unallowable Expenditures and
            Unallowable Lost Revenues .......................................................................................... 12

RECOMMENDATIONS ................................................................................................................... 13

HEALTH RESOURCES AND SERVICES ADMINISTRATION COMMENTS .......................................... 13

APPENDICES

           A: Audit Scope and Methodology ..................................................................................... 14

           B: Related Office of Inspector General Reports................................................................ 17

           C: Provider Relief Fund General and Targeted Distribution Payments ............................ 18

           D: Options for Calculating Lost Revenues......................................................................... 20


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)
        E: Selected Nursing Facilities’ Reported Use of CY 2020 Provider Relief Fund
          Payments ........................................................................................................................ 21

        F: Summary of Sampled Nursing Facilities’ Unallowable or Potentially
          Unallowable Amounts .................................................................................................... 22

        G: Health Resources and Services Administration Comments ......................................... 24




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)
                                                INTRODUCTION

WHY WE DID THIS AUDIT

On March 13, 2020, the President declared the COVID-19 outbreak a national emergency. In
response, Congress passed three bills, which the President signed into law. These Federal laws
appropriated to the Department of Health and Human Services (HHS) a combined $178 billion
in funds, which HHS used to establish the Provider Relief Fund (PRF). 1 The PRF provided
payments to eligible hospitals and other health care providers (collectively referred to as
“providers”) for: (1) health care-related expenses or lost revenue (e.g., due to canceled elective
services) attributable to COVID-19, (2) COVID-19 testing and treatment for uninsured
individuals, and (3) the administration of vaccines. HHS distributed PRF funds, in part, as direct
payments to providers in a series of PRF General and Targeted Distributions. 2 As of October
2024, the Health Resources and Services Administration (HRSA) had distributed $145.9 billion of
the PRF to providers. 3

This audit assessed selected nursing facilities’ compliance with terms and conditions and
Federal requirements for expending PRF payments. It is one of several Office of Inspector
General (OIG) audits of various aspects of PRF payments, including: (1) HHS’s and HRSA’s
controls related to the requirements for submitting revenue information and attesting to the
acceptance or rejection of PRF payments, (2) HHS’s and HRSA’s controls over PRF payment
calculations and provider eligibility determinations, and (3) claims for COVID-19 testing and
treatment services for uninsured individuals. See Appendix B for a list of related OIG reports.

OBJECTIVE

Our objective was to determine whether selected nursing facilities that received PRF payments
complied with terms and conditions and Federal requirements for expending PRF funds.



1
  Specifically, the Coronavirus Aid, Relief, and Economic Security Act, P.L. No. 116-136, signed into law on Mar.
27, 2020, appropriated $100 billion; the Paycheck Protection Program and Health Care Enhancement Act, P.L. No.
116-139, signed into law on Apr. 24, 2020, appropriated $75 billion; and the Consolidated Appropriations Act, 2021,
P.L. No. 116-260, signed into law on Dec. 27, 2020, appropriated $3 billion.

2
 Under the General Distributions, PRF payments were distributed in four phases (Phases 1, 2, 3, and 4). For
example, under the Phase 1 General Distribution, PRF payments were distributed to eligible Medicare providers
that billed Medicare fee-for-service (Medicare Parts A or B) in calendar year (CY) 2019. Under the Targeted
Distributions, PRF payments were made to eligible providers or specific provider types to address added COVID-19
challenges, such as high-need populations, including nursing facilities and providers serving individuals in rural
areas and safety net hospitals.

3
 This dollar figure is based on latest PRF distribution data provided by HRSA. As of June 2023, with the passage of
the Fiscal Responsibility Act of 2023, P.L. No. 118-5, Congress rescinded some unobligated PRF funds,
notwithstanding limited funding Congress directed to be used for program oversight and administration. In
response, HRSA stopped making PRF payments to providers.


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BACKGROUND

The Provider Relief Fund

As a result of the COVID-19 public health emergency, many States ordered health care facilities,
physicians, and other providers and professionals to delay elective or nonurgent procedures to
conserve personal protective equipment (PPE) and free up staff and facilities for COVID-19
patients.4 Nursing facilities subsequently experienced decreased admissions in addition to
increased costs (e.g., for staffing, PPE and other supplies, routine testing, and other expenses).
Nursing facilities and their residents were among the hardest hit by the COVID-19 pandemic,
due in part to the residents’ advanced age and underlying medical conditions, close living
quarters, and nursing facilities’ longstanding staffing and infection control challenges.5, 6
During COVID-19 surges in the spring and fall of 2020, more than 1,300 nursing facilities had
infection rates of 75 percent or more among residents enrolled in Medicare. 7

In response to the public health emergency, the PRF was established to provide funds to
eligible providers for health care-related expenses or lost revenue attributable to COVID-19.8
HHS received a combined $178 billion in funding, of which $145.9 billion was distributed via PRF
payments to providers. 9 PRF funds were distributed as direct payments to providers in a series
of General and Targeted Distributions.

The Exhibit on the next page details these PRF distributions to health care providers. For
further details on how PRF payments were distributed, see Appendix C.




4
 On Jan. 31, 2020, the Secretary of Health and Human Services declared the COVID-19 outbreak a public health
emergency. Then, on Mar. 13, 2020, the President declared the COVID-19 outbreak a national emergency. Both
the COVID-19 public health and national emergencies ended on May 11, 2023.

5
 Government Accountability Office (GAO), COVID-19 in Nursing Homes: Most Homes Had Multiple Outbreaks and
Weeks of Sustained Transmission from May 2020 through January 2021 (GAO-21-367). Accessed on Apr. 2, 2025.

6
 GAO, COVID-19: Federal Efforts Could Be Strengthened by Timely and Concerted Actions (GAO-20-701). Accessed
on Apr. 2, 2025.

7
 OIG, More Than a Thousand Nursing Homes Reached Infection Rates of 75 Percent or More in the First Year of the
COVID-19 Pandemic; Better Protections Are Needed for Future Emergencies (OEI-02-20-00491), Jan. 19, 2023.

8
 Providers had up to the end of the quarter in which the public health emergency ended (June 30, 2023) to use
PRF payments for any health care-related expenses or lost revenues attributable to COVID-19.

9
 Congress also appropriated $8.5 billion of COVID-19-related relief for rural providers enrolled in Medicare or
Medicaid programs (American Rescue Plan Act of 2021, P.L. No. 117-2). This funding was administered by HRSA
and had similar limitations and requirements as the PRF but was not part of the PRF.


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                Exhibit: Provider Relief Fund Distributions to Health Care Providers




Notes: Amounts for the Targeted Distributions do not add to $57.5 billion due to rounding. CHIP stands for the
Children’s Health Insurance Program.

HHS’s and HRSA’s Oversight of the Provider Relief Fund Program

The HHS Office of the Secretary was responsible for initial PRF program oversight and policy
decisions. The HHS Office of the Secretary’s direct responsibility for the PRF allowed HHS to
meet its mission to expedite the establishment of the PRF and the distribution of funds as
quickly as possible for providers’ health care-related expenses or lost revenues attributable to




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                            3
COVID-19. Within HHS, HRSA was responsible for providing day-to-day oversight and managed
all aspects of the PRF program. 10

HRSA provided various resources to providers on the proper use and reporting of PRF
payments, including issuing a collection of evolving Frequently Asked Questions (FAQs), and
other guidance on allowable expenses and lost revenues calculations.11 HRSA also conducted
technical assistance webinars on the reporting process. In addition, HRSA engaged external
audit firms to conduct risk-based audits for a sample of providers to ensure that providers used
PRF payments in accordance with PRF terms and conditions.

Requirements for Nursing Facilities That Received Provider Relief Fund Payments

Providers, including nursing facilities, may have been eligible to receive PRF payments from
multiple distributions. 12 For example, nursing facilities may have received PRF payments
through the following distributions:

       •   Skilled Nursing Facilities (SNFs) Targeted Distribution 13 and

       •   Nursing Home Infection Control (NHIC) Targeted Distribution that included: (1) direct
           payments to SNFs and nursing homes to build skills and enhance response to COVID-19,
           including improved infection controls, 14 and (2) an incentive payment structure called




10
     HHS and HRSA, PRF General & Targeted Distribution Cycle Memo, dated Sept. 30, 2020, and Sept. 30, 2021.

11
  HRSA, “Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions” (PRF
FAQs). Accessed on Apr. 2, 2025. HRSA, “Provider Relief Fund Distributions and American Rescue Plan Rural
Distribution Post-Payment Notice of Reporting Requirements” (PRF Reporting Requirements). Accessed on Apr. 2,
2025.

12
  PRF payments were distributed to providers based on providers’ taxpayer identification numbers (TINs). Nursing
facilities and other providers were required to report on their PRF payments if they received $10,000 or more
during a specified timeframe (i.e., payment period). For providers to meet this requirement, HRSA established
reporting periods, which specified when providers had to report on the use of PRF payments and were based on
the payment period(s). For example, reporting periods 1 and 2 covered PRF payments received during CY 2020.
We use the term “nursing facility” to refer to a nursing facility reporting entity. A nursing facility reporting entity
may have registered its TIN through the PRF Reporting Portal to report to HRSA on the use of PRF payments
received by that TIN and TINs associated with the entity’s subsidiary entities (e.g., individual nursing facilities). A
nursing facility may be a stand-alone nursing facility or part of a parent-subsidiary system that may include a parent
company and various provider types (e.g., hospitals, clinics, urgent care facilities, and physician groups).

13
   SNFs that were certified under Medicare, Medicaid, or both and had at least six certified beds were deemed
eligible to receive a Targeted SNF Distribution that included a fixed distribution per facility of $50,000 plus
distribution of $2,500 per bed.



Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                                 4
         the Quality Incentive Payment Program that provided more funding to nursing homes
         and SNFs based on certain performance measures.

Nursing facilities could have also received payments from the General and other Targeted
Distributions.15

Throughout the report, we refer to:

     •   a SNF Targeted Distribution as a “SNF Distribution”;

     •   an NHIC Targeted Distribution as an “NHIC Distribution”; and

     •   General and non-NHIC Targeted Distributions, including the SNF Distribution, as “non-
         NHIC Distributions.” 16

We refer to all General and Targeted Distributions together as “PRF payments.”

Nursing facilities that received and kept PRF payments had to comply with certain provisions of
the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS
Awards (45 CFR part 75). Specifically, the nursing facilities had to comply with 45 CFR § 75.302
(Financial management and standards for financial management systems) and 45 CFR §§ 75.361
through 75.365 (Record retention and access).

As a condition of receiving and retaining PRF payments, nursing facilities were required to
attest to the relevant PRF terms and conditions, including meeting eligibility criteria; filing
expenditure reports; and ensuring that payments were: (1) not used to reimburse expenses or
losses already reimbursed from other funding sources and (2) not used to pay salaries in excess
of a certain threshold or to pay for certain prohibited activities (e.g., lobbying). 17


14
  Nursing homes and SNFs that were not revoked (i.e., the Centers for Medicare & Medicaid Services [CMS] did not
revoke Medicare enrollment of a provider for reasons such as noncompliance with enrollment requirements,
provider or supplier conduct, and others) had an active CMS certification, and had at least six certified beds were
deemed eligible to receive a Targeted NHIC Distribution that included a fixed distribution per facility of $10,000
plus distribution of $1,450 per bed.

15
  For details on General and Targeted Distribution payments, see Appendix C. In addition to PRF payments, we
note that nursing facilities could have received COVID-19-related assistance from the Federal Emergency
Management Agency, the Department of the Treasury, and the Small Business Administration, as well as from
grants and donations from local and State governments or private sources.

16
  The terms and conditions for the NHIC Distribution differ from those for the non-NHIC Distribution. Therefore,
throughout the report we distinguish between the NHIC Distribution and the non-NHIC Distribution.

 Recipients were not allowed to use PRF payments to pay any salary at a rate in excess of Executive Level II, which
17

was set at $197,300 for 2020 and $199,300 for 2021.


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The terms and conditions for the non-NHIC Distribution required providers to certify that
payments were: (1) used to prevent, prepare for, or respond to COVID-19 and (2) used for
health care-related expenses or lost revenues (i.e., patient care revenues) attributable to
COVID-19. 18

The terms and conditions for the NHIC Distribution required providers to attest that the
payments would be used for infection control expenses associated with the following items and
services: (1) administering COVID-19 testing; (2) reporting COVID-19 results to local, State, and
Federal governments; (3) hiring staff to provide patient care or administrative support;
(4) improving infection controls; and (5) providing additional services to residents (e.g.,
technology that permits residents to connect with their families if the families are unable to
visit in person).

Provider Relief Fund Expenditures and Lost Revenues

For reporting purposes, HRSA established periods during which providers were required to use
and report on PRF payments.19 Providers, including nursing facilities, were required to report
on their use of PRF payments in broad categories (i.e., lost revenues, health care-related
expenses, or general and administrative expenses). For expenses, nursing facilities were
required to report their use of PRF payments for health care-related expenses (e.g., expenses
for purchasing equipment such as ventilators and sanitizing supplies for infection control) and
general and administrative expenses (e.g., salaries, utilities, rent), including expenses incurred
prior to receipt of PRF payments (i.e., pre-award costs dated back to January 1, 2020). 20
Nursing facilities were also required to use NHIC Distribution payments for costs associated
with infection control expenses. Nursing facilities were required to follow their basis of
accounting (cash or accrual basis) to determine expenses and only use PRF payments for
eligible expenses or lost revenues during what is known as the period of availability. 21

For lost revenues, nursing facilities could apply their non-NHIC Distribution payments toward
lost revenue amounts during a period of availability calculated using one of the following three
options:



18
  Patient care means health care, services, and supports as provided in a medical setting, at home, via telehealth,
or in the community. Items not considered patient care revenue include nonpatient care dining services, grants,
bad debt, any gains or losses on investments, and contractual adjustments.

19
   HRSA required all providers that received PRF payments exceeding $10,000 in the aggregate during any of these
periods to report on their use of the payments during the applicable reporting period.

20
     HRSA, PRF Reporting Requirements.

21
  The period of availability ends 1 year after the end of the quarter or semiannual period in which the payment
was received. The first payment receipt period was Apr. 10 through June 30, 2020. Subsequent payment receipt
periods were 6 months.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                                 6
       1. the difference between actual patient care revenues from 2019 and actual patient care
          revenues during the period of availability,

       2. the difference between budgeted patient care revenues (approved by nursing facility
          officials prior to March 27, 2020) and actual patient care revenues, or

       3. any reasonable method of estimating revenues. 22

Nursing facilities were not allowed to use NHIC Distribution payments to offset lost revenues. 23

HRSA guidance for the treatment of unallowable or ineligible expenditures of PRF funds stated
that providers were allowed to replace unallowable or ineligible expenditures allocated to PRF
payments in a closed reporting period with unreimbursed lost revenues in subsequent
reporting periods. Providers are not required to return PRF payments used for unallowable
purposes (e.g., lobbying) to the Federal Government if they have sufficient unreimbursed lost
revenues to offset unallowable amounts. See Appendix D for a detailed description of how
providers could choose to calculate lost revenue.

HOW WE CONDUCTED THIS AUDIT

Our audit covered $291 million in non-NHIC Distribution payments and related interest and $94
million in NHIC Distribution payments and related interest to a nonstatistical sample of 30
nursing facility taxpayer identification numbers (TINs) during calendar year (CY) 2020.24 (We
refer to these sample units throughout the report as “nursing facilities.”) 25 The selected nursing
facilities reported that they used $160 million of their PRF payments for health care-related
expenses, $116 million to offset lost revenues, and $95 million for general and administrative
expenses. The remaining $14 million was returned to HRSA because nursing facilities did not



22
  For payments received in Periods 5, 6, or 7, the period of availability to use PRF payments for lost revenues
attributable to COVID-19 ended June 30, 2023, the end of the quarter in which the COVID-19 public health
emergency ended (HRSA, PRF Reporting Requirements).

23
     HRSA, “Nursing Home Infection Control Distribution.” Accessed on Apr. 2, 2025.

24
  Some nursing facilities kept their PRF payments in an interest-bearing account and included interest in the
amounts reported on expenditure reports submitted to HRSA.

25
  The sampling frame consisted of 12,927 nursing facilities that: (1) received and kept SNF Distribution payments,
NHIC Distribution payments, or both and (2) were not covered by any HHS-OIG, HRSA, or Pandemic Response
Accountability Committee (PRAC) projects. The total PRF payments (General and Targeted Distributions) to these
TINs was $23.6 billion. PRF payment recipients had 90 days (or 45 days for Targeted SNF Distributions) to return a
payment to HHS, otherwise the recipient was deemed to have accepted the terms and conditions. Our sample
included nursing facilities that received PRF payments issued in CY 2020 and for which nursing facilities attested to
the payment terms and conditions or were deemed to have accepted the terms and conditions.



Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                                   7
use these payments.26 Appendix E contains details on how the selected nursing facilities used
PRF payments issued in CY 2020.

We selected nursing facilities that received and kept SNF Distribution payments in period 1 and
NHIC Distribution payments in period 2.27 We selected nursing facilities based on an analysis
that considered the total amount of SNF and NHIC Distribution payments received and kept
along with geographic location (urban and rural areas in various States). 28 We reviewed the
nursing facilities’ PRF payments used to offset lost patient care revenues or cover general and
administrative and health care-related expenses. Specifically, for each of the selected nursing
facilities that reported expenditures, we reviewed a nonstatistical sample of expenses that we
selected based on materiality and expense descriptions (e.g., salaries, supplies, equipment).
For the selected nursing facilities that reported lost revenues, we reviewed the nursing
facilities’ lost revenues calculations. 29

We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.

Appendix A describes our audit scope and methodology.

                                                     FINDINGS

Of the 30 selected nursing facilities, 20 used the funds for allowable general and administrative
and health care-related expenditures, for infection controls expenses, and to offset lost
revenues attributable to COVID-19. However, the remaining 10 nursing facilities did not comply
or may not have complied with Federal requirements. Specifically, eight nursing facilities used
PRF payments for unallowable expenditures or lost revenues. In addition, three nursing




26
  Nursing facilities reported these amounts on expenditure reports submitted to HRSA for reporting periods 1
and 2.

27
  To select nursing facilities for the audit, we only considered direct NHIC payments because not all nursing
facilities received quality incentive payments.

28
  Our sample unit was a nursing facility that reported the use of PRF payments. Each sampled nursing facility could
be a stand-alone nursing facility or part of a parent-subsidiary system that may include a parent company and
various provider types (e.g., hospitals, clinics, urgent care facilities, and physician groups). The 30 selected nursing
facilities each received PRF payments from $558,000 to $133 million during CY 2020 and are located in 23 States.
Appendix F contains details on the sampled nursing facilities.

29
  Of the 30 selected nursing facilities, 25 nursing facilities reported both expenses and lost revenues, and 5 nursing
facilities reported only expenses.


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facilities may have used PRF payments for unallowable expenditures. 30 These deficiencies
occurred because although nursing facilities attested to the PRF terms and conditions and HRSA
provided continuously updated guidance to PRF recipients, the nursing facilities did not always
maintain documentation to support reported expenditures, may have misinterpreted HRSA’s
guidance, made clerical errors, or did not effectively track expenses funded by PRF payments.

As a result of these deficiencies, 8 of the 30 selected nursing facilities used a total of $2,256,504
in PRF payments for unallowable expenditures and lost revenues. In addition, three nursing
facilities used a total of $332,562 in PRF payments for expenditures that may not have been
allowable. These funds could have been used to offset allowable lost revenues or to support
other activities related to the COVID-19 public health emergency, including preventing,
preparing for, and responding to COVID-19, as well as improving infection controls.

Appendix F contains a summary of our audit results for the sampled nursing facilities.

SOME NURSING FACILITIES USED PROVIDER RELIEF FUND PAYMENTS FOR UNALLOWABLE
EXPENDITURES AND LOST REVENUES

Unallowable Costs

As a condition of receiving and retaining PRF payments, nursing facilities were required to
attest to the relevant PRF terms and conditions, including meeting eligibility criteria; filing
expenditure reports; and ensuring that payments were: (1) not used to reimburse expenses or
losses already reimbursed from other funding sources and (2) not used to pay salaries in excess
of a certain threshold or to pay for certain prohibited activities (e.g., lobbying).

The terms and conditions for the non-NHIC Distribution required providers to certify that
payments were: (1) used to prevent, prepare for, or respond to COVID-19 and (2) used for
health care-related expenses or lost revenues (i.e., patient care revenues) attributable to
COVID-19.

The terms and conditions for the NHIC Distribution required providers to attest that the
payments would be used for infection control expenses associated with the following items and
services: (1) administering COVID-19 testing; (2) reporting COVID-19 results to local, State, and
Federal governments; (3) hiring staff to provide patient care or administrative support;
(4) improving infection controls; and (5) providing additional services to residents (e.g.,
technology that permits residents to connect with their families if the families are unable to
visit in person).




30
  Some nursing facilities had more than one deficiency. As a result, the total number of nursing facilities that used
or may not have used PRF payments for unallowable or unsupported expenditures or lost revenues does not add
up to 10.


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PRF recipients must comply with certain Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for HHS Awards (45 CFR part 75). The financial management system of
each PRF recipient must provide accurate, current, and complete disclosure of the financial
results of each Federal award or program. The PRF recipient’s records must identify the source
and application of funds for federally funded activities and be supported by source
documentation (45 CFR §§ 75.302(b)(2) and (3)).

Six sampled nursing facilities used $849,443 in PRF payments for the following unallowable
expenditures: 31

     •   Three nursing facilities used PRF payments to cover duplicate health care-related
         expenses of $29,328.

     •   One nursing facility used non-NHIC Distribution payments for legal expenditures totaling
         $386,743 due to civil and administrative proceedings against the facility. These
         expenditures were not attributable to COVID-19. The nursing facility stated that HRSA’s
         regulations and guidance did not specifically address legal expenditures due to civil and
         administrative proceedings against the facility.

     •   One nursing facility used non-NHIC Distribution payments totaling $289,657 for
         expenditures that were reimbursed from other sources. The nursing facility explained
         that it failed to remove expenditures covered by other grants from its PRF expenditure
         tracking sheet.

     •   One nursing facility used non-NHIC Distribution payments for an employee’s salary
         expense that exceeded the CY 2020 Executive Level II salary threshold by $91,076.

     •   One nursing facility reported PRF payments of $37,592 that exceeded actual expenses.

     •   One nursing facility used non-NHIC Distribution payments for landscaping expenditures
         of $15,047. The nursing facility explained that due to COVID-19, they did not have
         anyone to maintain a lot adjacent to their facility. These expenditures were not
         attributable to COVID-19.

Costs Not Adequately Supported

PRF recipients must comply with certain Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for HHS Awards (45 CFR part 75). The financial management system of
each PRF recipient must provide accurate, current, and complete disclosure of the financial
results of each Federal award or program. The PRF recipient’s records must identify the source
and application of funds for federally funded activities and be supported by source

31
  Some nursing facilities had more than one finding. As a result, the total number of nursing facilities that used
PRF payments for unallowable expenditures does not add up to six.


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documentation (45 CFR §§ 75.302(b)(2) and (3)).

Two sampled nursing facilities did not maintain sufficient records that supported reported
health care-related expenditures totaling $693,355. Specifically, the nursing facilities did not
maintain invoices, proof of payment (e.g., bank statements or canceled checks), or both to
support these expenditures.

Unallowable Use of Nursing Home Infection Control Provider Relief Fund Payments

The NHIC Distribution terms and conditions did not allow nursing facilities to use NHIC
Distribution payments to offset lost revenues.

One sampled nursing facility used $517,214 in NHIC Distribution payments to offset lost
revenues and reported the lost revenues as a facilities expense in its PRF report. The entity
explained that this was an oversight error in the data entry during the PRF reporting process.

Inaccurate Lost Revenue Calculation

Non-NHIC Distribution payment amounts not fully expended on health care-related expenses
attributable to COVID-19 may be applied to lost revenues. Lost revenues can be calculated by
one of three options, including comparing budgeted patient care revenues to actual patient
care revenues during CYs 2020 and 2021 (option 2). 32 Only nursing facilities that had a budget
that covered the entire period of availability and was approved prior to March 27, 2020, could
choose option 2 to calculate lost revenues.

One sampled nursing facility used option 2 to calculate lost revenues, but the facility did not
have a CY 2021 budget approved prior to March 27, 2020, for calculating its lost revenues for
CY 2021. 33 The nursing facility explained they did not use another option for calculating lost
revenues due to an error. As a result, the nursing facility used $196,492 in non-NHIC
Distribution payments to offset inaccurately calculated lost revenues.

SOME NURSING FACILITIES MAY HAVE USED PROVIDER RELIEF FUND PAYMENTS FOR
UNALLOWABLE EXPENDITURES

As a condition of receiving non-NHIC Distribution payments, nursing facilities agreed to ensure
that payments were used for purposes related to COVID-19. One of the allowable uses of non-



32
     See Appendix D for a detailed description of how providers could choose to calculate lost revenues.

33
  OIG reviewed the expenditure reports the nursing facility submitted to HRSA for reporting periods 1 and 2. The
expenditure reports indicated that option 2 was selected to account for lost revenues. OIG did not attempt to
determine whether any other option would be more reasonable to account for lost revenues incurred by the
nursing facility during our audit period.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                          11
NHIC Distribution payments was for mortgage and rent expenses defined by HRSA as rent for a
clinical setting, medical office building, and so forth. 34

As a condition of receiving NHIC Distribution payments, nursing facilities agreed to ensure that
payments were used for infection control expenses. One of the allowable uses of NHIC
Distribution payments was for mortgage and rent expense defined by HRSA as a payment
related to mortgage or rent for a facility specifically for infection control.35

The PRF recipient’s records must identify the source and application of funds for federally
funded activities and be supported by source documentation (45 CFR §§ 75.302(b)(2) and (3)).

Three sampled nursing facilities used PRF payments for mortgage and rent expenditures. The
nursing facilities incurred the mortgage and rent expenditures before the pandemic, and these
expenditures did not increase during the pandemic. Though the nursing facilities explained that
they modified or used a certain percentage of the building space for COVID-19- or infection
control-related needs, the nursing facilities were unable to provide documentation supporting
the utilization of the building space. The nursing facilities used PRF payments to cover their
entire monthly mortgage and rent expenditures. As a result, we were unable to determine
whether $332,562 in PRF payments were used for the allowable mortgage and rent
expenditures.

CAUSES FOR UNALLOWABLE AND POTENTIALLY UNALLOWABLE EXPENDITURES AND
UNALLOWABLE LOST REVENUES

These deficiencies occurred because although nursing facilities attested to the PRF terms and
conditions and HRSA provided continuously updated guidance to PRF recipients, the nursing
facilities did not always maintain documentation to support reported expenditures, may have
misinterpreted HRSA’s guidance, made clerical errors, or did not effectively track expenses
funded by PRF payments.

Further, in the context of extraordinary challenges from the COVID-19 public health emergency,
HRSA’s operational objective at the beginning of the public health emergency was to rapidly
disburse PRF payments to support providers facing severe economic hardship. According to the
nursing facilities, HRSA’s guidance was frequently updated and was not always clear.
Consequently, nursing facilities faced difficulties tracking allowable expenditures, reporting
expenditures and lost revenues with the required level of detail, and correcting expenditure
reports in the PRF Reporting Portal.

In addition to the recommendations below, key stakeholders and decisionmakers should use
the information included in this report when determining lessons learned from administering

34
     HRSA, “Allowable Expenses.” Accessed on Apr. 2, 2025.

35
     HRSA, “Nursing Home Infection Control Distribution.” Accessed on Apr. 2, 2025.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)           12
PRF distributions during the COVID-19 public health emergency and look for additional ways to
safeguard Federal funds when rapidly disbursing assistance payments to providers in response
to future public health emergencies.

                                           RECOMMENDATIONS

We recommend that the Health Resources and Services Administration:

    •   require the eight nursing facilities that we determined as having used PRF payments for
        unallowable expenditures and lost revenues totaling $2,256,504 to return the
        unallowable amounts to the Federal Government or ensure that the nursing facilities
        properly replace the unallowable expenditures and lost revenues with allowable
        unreimbursed lost revenues or eligible expenses, if any, and

    •   work with the three nursing facilities that we determined as having used PRF payments
        for potentially unallowable expenditures totaling $332,562 to identify and return the
        unallowable amounts to the Federal Government or ensure that the nursing facilities
        properly replace the unallowable expenditures with allowable unreimbursed lost
        revenues or eligible expenses, if any.

                HEALTH RESOURCES AND SERVICES ADMINISTRATION COMMENTS

In written comments on our draft report, HRSA concurred with our recommendations and
indicated that it will review supporting documentation and seek repayment, as appropriate.

HRSA also provided technical comments, which we addressed as appropriate. HRSA’s
comments, excluding the technical comments, are included as Appendix G.




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)         13
                              APPENDIX A: AUDIT SCOPE AND METHODOLOGY

SCOPE

We identified 12,927 nursing facilities that: (1) received and kept SNF Distribution payments,
NHIC distribution payments, or both during CY 2020 and (2) were not covered by any HHS-OIG,
HRSA, or PRAC projects.36 The PRF payments to these nursing facilities totaled $23.6 billion.
We selected for audit a nonstatistical sample of 30 nursing facilities that received and kept
$291 million in non-NHIC Distribution payments and related interest in period 1 and $94 million
in NHIC Distribution payments and related interest in period 2. 37 We selected nursing facilities
based on a risk analysis that considered the total amount of SNF and NHIC Distribution
payments received and kept along with geographic location (urban and rural areas in various
States). 38, 39 We reviewed the selected nursing facilities’ use of PRF payments received from
non-NHIC and NHIC Distributions.

We limited our review of HRSA’s and the selected nursing facilities’ internal controls to those
applicable to our audit objective. We did not assess HRSA’s or the nursing facilities’ overall
internal control structure. Specifically, we reviewed HRSA’s policies and procedures for
reviewing expenditure information submitted by providers and its guidance to providers on the
use and reporting of PRF payments. We also reviewed the selected nursing facility providers’
policies and procedures for monitoring, tracking, and expending PRF payments.

We established reasonable assurance of the authenticity and accuracy of the PRF payment data
by reconciling it with PRF expenditure reports nursing facilities submitted through HRSA’s PRF
Reporting Portal.

We conducted our audit from May 2022 through December 2024.




36
  The Coronavirus Aid, Relief, and Economic Security Act created the PRAC within the Council of the Inspectors
General on Integrity and Efficiency to promote transparency and conduct and support oversight of covered funds
and the COVID-19 response to: (1) prevent and detect fraud, waste, abuse, and mismanagement and (2) mitigate
major risks that cut across program and agency boundaries.

37
  PRF payment recipients had 90 days (or 45 days for Targeted SNF Distributions) to return a payment to HHS;
otherwise, the recipient was deemed to have accepted the terms and conditions. Our sample included nursing
facilities that received both SNF and NHIC Distribution payments issued in CY 2020 for which nursing facilities
attested to the payment terms and conditions or were deemed to have accepted the terms and conditions.

38
  To select nursing facilities for the audit, we only considered direct NHIC payments because not all nursing
facilities received quality incentive payments.

39
     We also analyzed the attestation status during the sample selection process.



Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                             14
METHODOLOGY

To accomplish our objective, we:

       •   reviewed applicable Federal laws, regulations, and guidance, including the PRF terms
           and conditions and HRSA’s FAQs related to providers’ use of PRF payments;

       •   met with HRSA officials to gain an understanding of the PRF’s payment terms and
           conditions, reporting requirements, and HRSA’s monitoring and oversight activities;

       •   reviewed HRSA’s policies and procedures related to its oversight of recipients’ reporting
           on the use of PRF funds and compliance with the terms and conditions for PRF
           payments;

       •   obtained PRF payments data for General and Targeted Distributions to nursing facilities
           in CY 2020;

       •   compiled a list of 12,927 nursing facilities that received and kept SNF Distribution
           payments, NHIC Distribution payments, or both in CY 2020 and were not covered by any
           HHS-OIG, HRSA, or PRAC projects;

       •   selected a nonstatistical sample of 30 nursing facilities (that received and kept SNF
           Distribution payments in period 1 and NHIC Distribution payments in period 2) based on
           the total amount of SNF and NHIC Distribution payments received and geographic
           locations (urban and rural areas in various States); 40, 41

       •   for each nursing facility selected for audit, interviewed nursing facility officials; reviewed
           its expenditure reports submitted to HRSA and a nonstatistical sample of expenses
           based on materiality and expense descriptions; and analyzed supporting accounting,
           personnel, and other records to determine whether:

                o non-NHIC Distribution payments were used only to prevent, prepare for, and
                  respond to COVID-19;

                o non-NHIC Distribution payments were used for health care-related or general
                  and administrative expenses or were applied to offset eligible lost revenues
                  attributable to COVID-19, and whether the amount for any lost revenues applied
                  toward PRF payments was accurately calculated; 42

40
  To select nursing facilities for the audit, we only considered direct NHIC payments because not all nursing
facilities received quality incentive payments.

41
     We also analyzed the attestation status during the sample selection process.

42
     We recalculated lost revenue amounts using the same option that the entity used for determining lost revenues.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                            15
             o NHIC Distribution payments were used only for infection control expenses;

             o PRF payments were not used to pay for expenses or lost revenues reimbursed by
               other funding sources (e.g., reimbursements from the Federal Emergency
               Management Agency, Medicare/Medicaid or commercial health insurance, the
               Paycheck Protection Program, and assistance from State or local government
               agencies); and

             o PRF payments were not used to pay salaries at a rate in excess of certain
               thresholds or for other prohibited activities; and

    •   discussed the results of our audit with HRSA officials.

We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)         16
                 APPENDIX B: RELATED OFFICE OF INSPECTOR GENERAL REPORTS


                            Report Title                                 Report Number     Date Issued

 Selected Home Health Agencies Complied With Terms and
 Conditions and Federal Requirements for Provider Relief                  A-01-22-00503    11/26/2024
 Fund Payments
 Seven of Thirty Hospices Reviewed Did Not Comply or May
 Not Have Complied With Terms and Conditions and                          A-02-22-01014    11/8/2024
 Federal Requirements for Provider Relief Fund Payments
 HRSA Made Some Potential Overpayments to Providers
 Under the Phase 2 General Distribution of the Provider                   A-09-22-06001     3/4/2024
 Relief Fund Program
 The Provider Relief Fund Helped Select Nursing Homes
 Maintain Services During the COVID 19 Pandemic, but                     OEI-06-22-00040   12/12/2023
 Some Found Guidance Difficult To Use
 HHS’s Oversight of Automatic Provider Relief Fund
 Payments Was Generally Effective But Improvements                        A-02-20-01025    10/30/2023
 Could Be Made
 HRSA Made COVID-19 Uninsured Program Payments to
 Providers on Behalf of Individuals Who Had Health
                                                                          A-02-21-01013    7/13/2023
 Insurance Coverage and for Services Unrelated to
 COVID-19
 Targeted Provider Relief Funds Allocated to Hospitals Had
 Some Differences With Respect to the Ethnicity and Race                 OEI-05-20-00580   7/12/2023
 of Populations Served
 HHS's and HRSA's Controls Related to Selected Provider
                                                                          A-09-21-06001    9/26/2022
 Relief Fund Program Requirements Could Be Improved




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                  17
     APPENDIX C: PROVIDER RELIEF FUND GENERAL AND TARGETED DISTRIBUTION PAYMENTS

As of October 2024, HRSA distributed $145.9 billion of the $178 billion appropriated to HHS for
the PRF. Of the $145.9 billion, $88.4 billion was distributed in General Distributions and $57.5
billion was distributed in several Targeted Distributions. A portion of the remaining $32.1
billion was distributed or allocated for HRSA’s program for uninsured individuals, the COVID-19
Coverage Assistance Fund, and Phase 4 General Distribution payments. 43

General Distributions

HRSA made General Distributions in four phases to health care providers, including Medicare
providers; providers participating in Medicaid, the Children’s Health Insurance Program (CHIP),
or Medicaid managed care plans; dentists; assisted living facilities; and behavioral health
providers.

      •   Phase 1 General Distribution: HRSA distributed $48.5 billion to providers in two rounds
          under the Phase 1 General Distribution for eligible providers that billed Medicare fee-
          for-service. These funds were allocated proportional to providers’ share of annual
          patient service revenues.

      •   Phase 2 General Distribution: HRSA distributed $5 billion in the Phase 2 General
          Distribution to Medicaid, CHIP, and dental providers, as well as assisted living facilities
          and certain Medicare providers that did not receive a Phase 1 General Distribution
          payment equal to 2 percent of their total patient care revenue or had a change in
          ownership in 2019 or 2020. Providers were required to apply for funding and included
          in their applications certain financial information related to documenting revenue
          necessary to determine the amount that a facility would receive.

      •   Phase 3 General Distribution: HRSA distributed $19.3 billion in the Phase 3 General
          Distribution to providers that had not received funding in prior distributions (i.e.,
          because they were new or because they were behavioral health providers not included
          in a prior allocation). Providers that had previously received PRF payments but had not
          received the full 2 percent of their annual patient revenue in PRF assistance were also
          eligible to apply for additional funds. Providers were required to apply for these funds.

      •   Phase 4 General Distribution: HRSA distributed approximately$15.6 billion in the Phase 4
          General Distribution to providers based on changes in revenues and expenses, as well as
          the amount and type of services provided to Medicare, Medicaid, and/or CHIP patients.
          Providers were required to apply for these funds.



43
  As of June 2023, with the passage of the Fiscal Responsibility Act of 2023, P.L. No. 118-5, Congress rescinded
unobligated PRF payments. In response, HRSA stopped making PRF payments to providers.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                              18
Targeted Distributions

HRSA also distributed PRF funds to target certain types of providers in CY 2020 that had high
needs due to COVID-19. These included the following:

     •   COVID-19 High-Impact Area Providers: HRSA distributed nearly $22 billion in COVID-19
         high-impact area payments to hospitals that had large numbers of COVID-19 inpatient
         admissions.44

     •   Safety Net Hospitals and Children’s Hospitals: HRSA distributed $13.3 billion to safety
         net hospitals and acute care hospitals and $1.1 billion to children’s hospitals.

     •   Rural Providers: HRSA distributed $11.2 billion in rural payments to rural hospitals,
         including rural acute care general hospitals and critical access hospitals; rural health
         clinics; and Federally Qualified Health Centers located in rural areas, including specialty
         rural hospitals, urban hospitals with certain rural Medicare designations, and hospitals
         in small metropolitan areas.

     •   Tribal Hospitals, Clinics, and Urban Health Centers/Indian Health Service Providers: HRSA
         distributed $540 million in relief funds to Tribal hospitals, clinics, and urban health
         centers. These payments were based on operating expenses.

     •   Skilled Nursing Facilities and Nursing Homes: HRSA distributed $4.9 billion in skilled
         nursing facility distribution payments. Additionally, to help combat the devastating
         effects of COVID-19, HRSA distributed $4.5 billion to skilled nursing facilities and nursing
         homes nationwide, which included payments for infection control and quality incentive
         payments to nursing homes that created and maintained safe environments for their
         residents.




44
  Hospitals that treated 100 or more COVID-19 patients between Jan. 1 and Apr. 10, 2020, were eligible for the first
round of high-impact distributions. Hospitals that treated more than 160 COVID-19 patients between Jan. 1 and
June 10, 2020, were eligible for the second round of high-impact distributions.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                           19
                       APPENDIX D: OPTIONS FOR CALCULATING LOST REVENUES

  Providers, including nursing facilities, could use one of the following three options to calculate
  their lost revenues.

Lost Revenues
                            Option 1                          Option 2                         Option 3
   Options
                   The difference between
                      actual patient care
                                                    The difference between
 Definition of     revenues from 2019 and                                     Any reasonable method of
                                                  budgeted and actual patient
   Option          actual patient revenues                                      estimating revenues
                                                        care revenues
                     during the period of
                          availability
PRF Reporting                                                                             Alternate Reasonable
                   2019 Actual Revenue               2020 Budgeted Revenue
 Portal Option                                                                                Methodology
  Base Period
                            2019                           2020 or 2021                      Not prescribed
for Calculation
  Calculation        Actuals vs. Actuals
                                                        Budget vs. Actuals                   Not prescribed
    Method      (e.g., Q1 2020 vs. Q1 2019)
 Frequency of
                         Quarterly                            Quarterly                        Quarterly
  Calculation
                                                                                       Each quarter during the
 Duration of
              Each quarter during the                Each quarter during the           period of availability in
Lost Revenues
               period of availability                 period of availability          which lost revenues were
    Period
                                                                                              determined
 Service Lines                                                                       All patient care services (as
 To Include in All patient care services             All patient care services             appropriate for
  Revenues                                                                                  methodology)
    Budget
                    Not applicable                    Before March 27, 2020                  Not prescribed
Approval Date
  Source: HRSA, Provider Relief Fund Lost Revenues Guide – Reporting Period 1. Accessed on Apr. 2, 2025.




  Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                       20
             APPENDIX E: SELECTED NURSING FACILITIES’ REPORTED USE OF CY 2020
                             PROVIDER RELIEF FUND PAYMENTS




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)   21
         APPENDIX F: SUMMARY OF SAMPLED NURSING FACILITIES’ UNALLOWABLE OR
                        POTENTIALLY UNALLOWABLE AMOUNTS

                                           Unallowable or
     Sample       PRF Payment(s)                                                   Reason for Unallowable or
                                              Potentially
       No.          Received 45                                                 Potentially Unallowable Amount
                                         Unallowable Amount
       1              $69,504,170                      $37,592                        Unallowable costs
       2             $132,783,396                             ̶
       3              $34,374,989                    $285,420                    Potentially unallowable costs
       4              $42,613,522                      $26,985                   Potentially unallowable costs
       5              $13,924,575                               ̶
       6               $9,952,371                                 ̶
       7               $3,239,245                                   ̶
       8               $2,084,393                                     ̶
       9               $3,591,115                                       ̶
       10              $1,972,042                                         ̶
       11              $4,882,696                    $477,819                         Unallowable costs
       12              $4,810,657                                           ̶
       13              $3,752,113                    $304,393                    Unsupported and unallowable
                                                                                            costs
       14               $2,972,551                                          ̶
       15               $2,398,670                                          ̶
       16                $559,429                                           ̶
       17                $590,771                                           ̶
       18                $690,204                                     ̶
       19                $557,597                             $196,492              Inaccurate lost revenue
                                                                                          calculation
       20                $789,760                                           ̶
       21               $1,865,188                                          ̶
       22               $1,488,903                                    ̶
       23               $1,294,518                            $702,573           Unsupported and unallowable
                                                                                            costs
       24               $1,578,316                              $5,374                Unallowable costs
       25              $10,148,294                             $15,047                Unallowable costs
       26               $5,580,694                                    ̶
       27               $5,578,613                                      ̶
       28              $10,130,776                                        ̶
       29               $9,212,758                            $537,371             Unallowable use of NHIC
                                                                                  Distribution payments and
                                                                                 potentially unallowable costs

45
  The PRF payment included: (1) non-NHIC Distribution payments issued in period 1 and (2) NHIC Distribution
payments issued in period 2. The PRF payment amounts do not include related interest.


Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)                            22
                                           Unallowable or
   Sample         PRF Payment(s)                                          Reason for Unallowable or
                                              Potentially
     No.            Received 45                                        Potentially Unallowable Amount
                                         Unallowable Amount
      30               $1,747,335                                ̶
     Total           $384,669,661                      $2,589,066




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)               23
        APPENDIX G: HEALTH RESOURCES AND SERVICES ADMINISTRATION COMMENTS




Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)   24
Nursing Facilities’ Compliance With Provider Relief Fund Requirements (A-05-22-00012)   25
Report Fraud, Waste,
and Abuse
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Who Can Report?
Anyone who suspects fraud, waste, and abuse should report their concerns
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