On June 11, 2021, the Department of Health and Human Services (“HHS”) released an updated notice regarding the reporting requirements for recipients of Provider Relief Funds (“PRF”).
This notice supersedes the guidance released early this year, providing updated deadlines for the use of funds and timelines for reporting to the PRF reporting portal.
Highlights from this release include:
- Entities receiving more than $10,000, in the aggregate, in the payment received period are required to report through the portal.
- The period of availability of the funds is defined as the time period in which the funds must be utilized. This is noted in the chart below as the deadline by which time recipients must use funds. The notice states that the recipient will use their basis of accounting to determine when the expenses are to be applied against the funds. For example, a cash basis entity can only apply expenses paid for during the period of availability.
- Once the period of availability ends, the recipient has 90 days to complete their reporting on the PRF funds for that period through the portal. Below is the chart issued by HHS illustrating these deadlines:
Payment Received Period
|Deadline to Use Funds||Reporting Time Period|
|Period 1||April 10, 2020 to June 30, 2020||June 30, 2021||July 1, 2021 to September 30, 2021|
|Period 2||July 1, 2020 to December 31, 2020||December 31, 2021||January 1, 2022 to March 31, 2022|
|Period 3||January 1, 2021 to June 30, 2021||June 30, 2022||July 1, 2022 to September 30, 2022|
|Period 4||July 1, 2021 to December 31, 2021||December 31, 2022||January 1, 2023 to March 31, 2023|
- HHS provided guidance on the steps for reporting the use of funds. There are 6 steps defined in the guidance and are to be followed in this order:
1. Interest earned on PRF payments
2. Other assistance received
3. Use of Nursing Home Infection Control Distribution payments
4. Use of general and other targeted distribution payments
5. Net unreimbursed expenses attributable to Coronavirus
6. Lost revenues reimbursement
- HHS also updated the 12 data elements that will need to be submitted as part of the reporting package.
The portal is now open and the first time period for reporting underway. You can find a copy of the June notice at General and Targeted Distribution Post-Payment Notice of Reporting Requirements January 15, 2021 (hhs.gov).
In addition to this notice, HHS updated their Frequently Asked Question (“FAQ”) page, which provided little clarity on the outstanding questions from recipients and their auditors. One significant update in the FAQ is with regard to the audit requirements of commercial (for-profit) entities. The FAQ notes that a Single Audit would be required when the total annual awards expended are $750,000 or greater. This is a change from the previous guidance which utilized the phrase “awards received.” Here is a link to the PRF FAQ page - Provider Relief Fund General Information (FAQs) | HHS.gov.
So, what should you do now?
- If you have not done so already, sign up for access to the reporting portal.
- Review the 12 data elements and if you are in Period 1, start to gather the information for reporting.
Please contact us with any questions and we will be sure to alert you as more information is released.