One of the many sources of support to come from the Coronavirus Aid, Relief, and Economic Security (CARES) Act is the Provider Relief Fund (PRF). Many healthcare providers, including for-profit corporations, qualify and have received these funds. The funds come with requirements on how they can be spent, how they must be reported, and certain audit requirements. Understanding these rules is paramount for an entity to be in compliance with the award.
The Department of Health and Human Services (HHS) was appropriated approximately $175 billion to allocate to hospitals and other healthcare providers on the front line of the coronavirus response. There are two programs under this appropriation:
- The Provider Relief Fund which was created to assist with healthcare-related expenses or lost revenues due to COVID-19 and
- COVID-19 testing for the uninsured, which reimburses providers for testing and treating uninsured individuals with COVID-19.
There is much guidance available on the HHS website on the use of the funds and allowable expenses. Additional guidance is continually being released. The focus of this notice is reporting.
All recipients of the PRF payments are required to comply with the reporting requirements described in the award terms and conditions, which can be found online on the HHS website. Recipients who received greater than $10,000 will be required to submit information regarding the funds used for (1) healthcare related expenses attributable to coronavirus that are not reimbursed from other sources and/or other healthcare related expenses defined in the guidance; and/or (2) lost patient care revenues. The first reporting deadline was originally set for February 15, 2021 for funds expended through December 31, 2020, but has since been delayed in a communication from HHS on January 15, 2021. A second reporting is due on July 31, 2021 for funds expended through June 30, 2021.
In addition to the reporting described above, commercial entities that received $750,000 or greater in PRF have additional audit requirements. These entities are required to report an audit of these funds. The entities can fulfill this requirement with one of the following:
- A financial audit of the award(s) conducted in accordance with Government Auditing Standards (the “Yellow Book”); or
- An audit of the financial statements in accordance with 45 CFR Subpart F of the Uniform Guidance (a “single audit”).
At this time, there has been no guidance issued regarding the due date for these audit reports, though typical single audits are due within 9 months of the end of the entity’s fiscal year.
Stay tuned to Friedman’s website as additional guidance is released. Please contact your Friedman partner, or reach out to me directly with any questions.