The past year has presented many challenging situations for all businesses, and FQHCs have been hit especially hard with the COVID-19 pandemic. Throughout this time, they’ve seen shortages in PPE, staffing, and a demand for care like none other in their history. Fortunately, much funding has been made available to FQHCs to assist with their financial needs. While there is no lack of funding, there is a challenge that presents itself when receiving funding that is tied to salaries, such as the Paycheck Protection Program (PPP). Many FQHCs use their 330 grant funding toward their payroll.
This presents an interesting dilemma when also receiving funding to cover payroll expenses through the PPP program. The dilemma is that if 330 funds are being applied to payroll, where are the PPP funds being applied? CFOs and controllers in FQHCs need to give this careful consideration to not double dip into funding for a single employee. One solution is to track clinical staffing under the 330 grant while keeping salary caps in mind, then using the PPP funding for salaries of administrative and office staff. Another is to allocated only a portion of 330 grants to salary, say 50%, then have salary available to be allocated under the PPP funding. This solution also works well if you secure grant funding from another source to use toward salaries. Yet a third solution that is rarely used is to allocate 330 grant funding to expenses other than salary. 330 grant funding may be used for other operating expenses within the scope of your grant, it does not have to be used solely for salaries.
If you think compliance is expensive – try non-compliance.
Former US Deputy Attorney General Paul McNulty
If you are finding it difficult to apply your funding sources, this is an often overlooked solution. Ultimately, it is the health center’s responsibility to remain in compliance with all funding and provide the appropriate tracking and documentation. You should have appropriate policies and procedures in place for grant tracking and follow your own protocol. With the most recent round of PPP funding now available, it may be the perfect time to review your own internal procedures. Please reach out to BCA if you are struggling with policies, procedures, or compliance with grant tracking.