Compliance Briefing — March 27, 2020
The U.S. CARES Act became law, expanding telehealth reimbursement, establishing relief funds, and creating new data reporting and privacy considerations for covered entities and financial institutions.
Executive briefing: The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on . The 880-page statute expands telehealth reimbursement and HIPAA flexibilities, creates relief funding programs, and directs new reporting and oversight mechanisms for healthcare providers, small businesses, and financial institutions.
Why it matters: Covered entities and lenders must adjust compliance processes to meet CARES Act conditions, including data reporting for relief programs, audit readiness for stimulus funds, and privacy safeguards for expanded telehealth usage.
- Update telehealth workflows: Align billing and consent processes with expanded Medicare telehealth coverage while maintaining HIPAA safeguards for remote care.
- Track relief fund conditions: Document eligibility and reporting requirements for Provider Relief Fund and Small Business Administration programs, including data retention for audits.
- Strengthen privacy controls: Ensure remote care tools and financial servicing platforms apply least-privilege access and encryption for increased sensitive data handling.
- Monitor agency guidance: Follow HHS, SBA, and Treasury guidance as they clarify program rules and enforcement expectations.
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