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Heather Alleva, associate in the firm's Healthcare section, is quoted in the Part B News article, "Provider Relief Fund audits coming; pick your method and keep good records."

"Document everything that you’re spending the funds on and make sure that you’re only spending it for the appropriate reasons," advises Heather Alleva, an associate with the law firm Buchanan Ingersoll & Rooney PC in Philadelphia.

Many providers have come to Alleva with concerns that have inadvertently taken too much money. "Often, it’s coming in because the provider has had some type of change in the past year, either by selling or retiring a practice or changing some of the services they provide," Alleva says. "So they worry that their financial information didn’t properly reflect all of their revenue because at the time the application was submitted, they were in the middle of some sale or acquisition."

But generally speaking, if your reporting and documentation is honest and complete, and your expenditure of the funds meets the requirements, you should be good, "even if the financials of that organization might be different now because they’ve sold or closed or cease operations of a practice," Alleva says.

Given the PRF’s broad definition of COVID-related issues, the providers with the most genuine cause for concern would-be those who never had any real access to such issues —"if you’re exclusively a behavioral health provider, for example, and you incur costs because you switch to telehealth," Alleva says. Or you might be "a boutique concierge medicine provider who does some type of specialty care and they just never deal with COVID cases."