Designing Program Integrity Strategy for COVID-19 Grants

Through the CARES Act of 2020 and subsequent legislation, nearly $200 billion was made available through the Provider Relief Fund (PRF) to support healthcare providers during the COVID-19 pandemic. The Health Resources and Services Administration (HRSA) was responsible for rapidly standing up the program and distributing funds to providers at a time of extraordinary need. Because the PRF was a new program operating on an accelerated timeline, many traditional program integrity controls had not yet been established. HRSA therefore faced the challenge of balancing rapid payment distribution with the need to safeguard federal funds and identify potential payment risks.

Emendata supported HRSA in developing and implementing a comprehensive program integrity strategy for the Provider Relief Fund. Our team evaluated payment methodologies, program requirements, and operational processes to identify potential sources of risk, then performed analyses to quantify the scope and financial impact of those risks across billions of dollars in distributed funds. The team also supported the design and implementation of HRSA's repayment processes, providing analytical, operational, and policy support throughout the repayment lifecycle. This included technical assistance for repayment activities, analyses to support appeals and case resolution, preparation of policy and decision memoranda for leadership review, and responses to oversight and external inquiries.

These efforts equipped HRSA with a mature program integrity capability for the Provider Relief Fund that balanced effective oversight with the operational realities of a rapidly deployed emergency program. The resulting analyses supported repayment actions, informed policy and operational decisions, and helped safeguard billions of dollars in distributed grants that supported healthcare providers during a pandemic.