New Provider Relief Fund Reporting Requirements and Timelines
Updated Reporting Guidelines
On June 11, 2021, the U.S. Department of Health and Human Services (HHS) and Health Resources and Services Administration (HRSA) released updated FAQs and Post-Payment Notice of Reporting Requirements. These updates include new spending and reporting deadlines based on the dates that funds were received. The new reporting requirements apply to Provider Relief Fund (PRF) General and Targeted Distributions (including the Skilled Nursing Facilities (SNF) and Nursing Home Infection Control Distribution). They do not apply to the Rural Health Clinic COVID-19 Testing Program or claim reimbursements from the HRSA COVID-19 Uninsured Program and the HRSA COVID-19 Coverage Assistance Fund (CAF).
HHS established new spending deadlines for provider relief funds based on the date the funds were received. Funds distributed between April 10 and June 30, 2020 (the majority of PRF funds were distributed between these dates) still have the original June 30, 2021 deadline for funds to be spent. HHS has stated that no extensions or exceptions will be made to this deadline. Funds received later in 2020 or in 2021 have later spending deadlines. Any funds not spent by the relevant deadlines must be returned to HHS through the Reporting Portal.
HHS did clarify in the Frequently Asked Questions (FAQs) that recipients may use payments for eligible expenses incurred prior to the receipt of those payments as long as they are to prevent, prepare for, and respond to COVID-19.
Providers who receive $10,000 or more in PRF funds in any Payment Received Period are required to report on the use of the funds using their normal basis of accounting (e.g. cash basis or accrual basis) in the PRF Reporting Portal. Reporting deadlines were extended from the originally communicated 30 days to 90 days after each spending deadline. If a provider cannot expend its Provider Relief Fund payments by the applicable deadline to use the funds, it must return any unused funds within 30 calendar days after the end of the applicable Period of Reporting.
As of July 1, 2021, the PRF Reporting Portal is open for recipients who are required to report during Reporting Period 1. In FAQs published on 07/01/2021, HHS provided new guidance on several important issues.
- HHS emphasized the importance of maintaining adequate documentation of eligible expenses.
- HHS clarified that tangible items purchased using PRF Payments do not have to be in the provider’s possession to be considered an eligible expense, but the cost must be incurred before the deadline to use the funds (this would be applicable to capital equipment purchased but not received by the deadline).
- If a provider has submitted an application for relief to FEMA, but has not yet received the FEMA funds, the provider should not report the requested FEMA amounts in the Provider Relief Fund report.
- HHS announced that when using Option I (2020 and 2021 Actuals vs 2019 Actuals) or Option II (2020 Actual vs 2020 budget) to calculate lost revenue, lost revenues are calculated for each quarter during the period of availability as a standalone calculation. There is no offset against quarters where no loss of revenue occurred. Quarters where there is lost revenue are added together to determine annual lost revenue.
- HHS provided a data entry worksheet that is designed to help prepare providers for data entry into the PRF Reporting Portal. The workbook is not required, but the workbook should make it very easy to populate the required data into the portal.
The data elements to be reported are substantially the same as HHS defined in the January 15, 2021 guidance. Recipients of SNF and Nursing Home Infection Control Payments will submit a consolidated report that distinguishes use of those funds from the use of General and Targeted Distributions.
HHS and HRSA hosted recorded Reporting Technical Assistance Sessions in July. The recording and slide deck are available on the HHS website. HHS has also made available a Provider Relief Fund Reporting Tutorial and a Provider Support Line – 866-569-3522.
On July 15, 2021, HHS released guidance related to the required Single Audit for PRF funds. Recipients that expend a total of $750,000 or more in federal funds (including PRF payments and other federal financial assistance) during their fiscal year are subject to Single Audit requirements, as set forth in the regulations at 45 CFR 75 Subpart F. HHS stated that Provider Relief Fund expenditures and/or lost revenue should be reported on a nonfederal entity’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal years ending on or after June 30, 2021.
The timing of SEFA reporting of Provider Relief Fund payments is as follows:
- For a FYE of June 30, 2021, and through FYEs of December 30, 2021, recipients are to report on the SEFA, the total expenditures and/or lost revenues from the Period 1 report submission to the Provider Relief Fund Reporting Portal.
- For a FYE of December 31, 2021, and through FYEs of June 29, 2022, recipients are to report on the SEFA, the total expenditures and/or lost revenues from both the Period 1 and Period 2 report submissions to the PRF reporting porta Provider Relief Fund Reporting Portal.
- For FYEs on or after June 30, 2022, SEFA reporting guidance related to Period 3 and Period 4 will be provided at a later date.
Also on July 15, 2021, in response to a question about appealing or disputing a PRF related decision made by HHS, HHS stated that it is developing a structured reconsiderations process to review and reconsider payment accuracy based on submitted supporting documentation. HHS will provide details in the coming weeks.
The link to the PRF Reporting Portal is: https://prfreporting.hrsa.gov/s/
The link to the HHS COVID-19 website is: https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html