As we continue to navigate the tumultuous waters of the COVID-19 “Coronavirus” Pandemic, Procor has reflected on current client engagements for public healthcare organizations working to manage the validity and ultimate reimbursement of significant COVID-related emergency expenses. This article will address some of the complications organizations face, specifically related to the demanding documentation requirements by the Federal Emergency Management Agency (“FEMA”) for emergency response activities. Also, Procor will provide recommendations on how to organize documentation in a manner to facilitate reimbursement.

Throughout the country, public healthcare organizations have invested billions of dollars in response to the rising COVID-19 cases. As a result, organizations have built temporary hospitals, purchased equipment, modified existing facilities, and retained 3rd-party staffing agencies – to name a few - all to attempt to reduce the number of infections and fatalities through this Pandemic.

To respond effectively, organizations have had to rely upon various vendors/contractors to perform these services, some of which have little experience in a ‘disaster’ environment, but nonetheless provide crucial services in this time of immense need. The result is inconsistent or insufficient documentation, which varies from contractor to contractor, vendor to vendor. Below, we have listed three essential tips that can make a significant difference for organizations facing these same challenges:

1) Provide a Narrative – The importance of including a brief description of the work performed with each invoice cannot be emphasized enough. Most costs will ultimately go through multiple levels of review and scrutiny, sometimes years in the future. Memorializing the work performed will help to facilitate this review process.

2) Do Not Forget Authorizations – Many organizations will require certain authorizations from their own personnel as well as from the senior staff of the vendors. These authorizations can be a signature on a timesheet or an attestation to the overall accuracy of an invoice. Excluding these authorizations can stall the entire review process.

3) Include ALL Receipts & Invoices – Many vendors will fail to provide receipts or invoices for materials and equipment costs that are ultimately passed on to their clients. These will be reviewed later on by FEMA, and/or other agencies and ‘materiality thresholds’ will be subjective. Therefore, in order to avoid the risk of having to go out-of-pocket to pay for potentially eligible reimbursable expenses, be sure to require all supporting documents from your vendors. And most importantly, make sure the receipts or invoices are actually included with your vendors’ invoice.