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HHS Delays Guidance on Reporting Requirements

Tiffany Karlin

August 17, 2020

As detailed in our prior client alert August 17th marked the day that Health and Human Services was prepared to announce the reporting requirements for Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000 in the aggregate from the PRF of the timing of future reporting requirements.  Unfortunately, as reported on their website, they are still refining the data elements and formulating a template that providers will need to submit.   We do not anticipate guidance to be released for another several weeks.

Notice of timing of reporting still remains unchanged:

  • The reporting system will become available to recipients for reporting on October 1, 2020.
  • All recipients must report within 45 days of the end of the calendar year 2020 on their expenditures through the period ending December 31, 2020.
  • Recipients who have expended funds in full prior to December 31, 2020, may submit a single final report at any time during the window that begins October 1, 2020, but no later than February 15, 2021.
  • Recipients with funds unexpended after December 31, 2020, must submit a second and final report no later than July 31, 2021.

Providers who were in receipt of any of the distributions below will be required to report:

General Distributions:

  • Initial Medicare Distribution
  • Additional Medicare Distribution
  • Medicaid, Dental & CHIP Distribution

Targeted Distributions:

  • High Impact Area Distribution
  • Rural Distribution
  • Skilled Nursing Facilities Distribution
  • Indian Health Service Distribution
  • Safety Net Hospital Distribution

Mueller Prost is monitoring this website several times a day to give you the latest information and provide you with the necessary training to comply with any requirements posted.  For more information on the delay, visit the HHS website.

In the mean time feel free to contact us directly with any questions!

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