Use of Funds: Could Reporting Entities have claimed the time spent by staff and director-level resources on COVID-19-specific matters, such as participating in task forces or preparing their health care organization’s COVID-19 response, that they would not have otherwise spent time on in the absence of the pandemic?

Time spent by staff on COVID-19-specific matters may be an allowable cost attributable to coronavirus so long as it was not reimbursed or obligated to be reimbursed by other sources. If the personnel salaries were reimbursed by any other source of funding they cannot be also reimbursed by the Provider Relief Fund or ARP Rural Distribution. In addition, no one individual may be allocated as greater than one full-time equivalent (FTE) across all sources of funding. All costs must have been tangible expenses (not opportunity costs) and supported by documentation.

The Reporting Entity must maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR §75.302 – Financial management and 45 CFR §75.361 through §75.365 – Record Retention and Access, and other information required by future program instructions to substantiate the reimbursement of costs under this award. The Recipient must promptly submit copies of such records and cost documentation upon the request of the Secretary, and the Reporting Entity agrees to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with these Terms and Conditions.

(Updated 10/27/2022)