apply to a penalty or proceeding under subsection (a) or (b) of such section. (d) Funding The Secretary shall provide for the transfer to the Centers for Medicare & Medicaid Program Management Account from the Federal Hospital Insurance Trust Fund and the Federal Supplementary Medical Trust Fund (in such portions as the Secretary determines appropriate) $100,000,000 for purposes of carrying out this section. (e) Report Not later than 3 years after the date of the enactment of this Act, the Inspector General of the Department of Health and Human Services shall submit to Congress a report containing an analysis of amounts paid pursuant to subsection (a)(1) compared to amounts paid to the Secretary pursuant to subsection (c). (f) Implementation Notwithstanding any other provision of law, the Secretary may implement the provisions of this section by program instruction or otherwise.