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HHS reporting requirements updated, and availability of funds adapted

Tiffany Karlin

June 14, 2021

On Friday, June 11, 2021, The Department of Health and Human Services (HHS) posted guidance and updates to their FAQs regarding reporting expectations for organizations who received Provider Relief Funding in 2020 and 2021. This update included reporting requirements and a published timeline for the permitted utilization of the Provider Relief Funding. See link to the HHS guidance here:  Reporting Requirements and Auditing | HHS.gov

The key factor now determining both the reporting requirement date(s) and the deadline for the availability/usage of funds will now be based on the date on which the Provider Relief Funds were received by your organization.  The payment is received on the deposit date for automated clearing house (ACH) payments or the check cashed date per guidance from HHS. Provider Relief Fund recipients are required to report in each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000, as indicated in the table below.

PeriodPayment Received PeriodDeadline to Use FundsReporting Time PeriodFunds Most Likely Include:
1April 10, 2020 to June 30, 2020June 30, 2021July 1, 2021 to Sept. 30, 2021General Funds Phases 1 & 2Allocation for Skilled Nursing (5/22)Rural Distributions & High Impact Funding Alloc. Tribal Hospitals, Clinics, & Urban Health Ctrs. (5/29)
2July 1, 2020 to Dec. 31, 2020Dec. 31, 2021Jan. 1, 2022 to Mar. 31, 2022General Funds Phases 2 & 3SNF Infection Control (8/27)Quality Incentive (Nov. – Dec.) High Impact & Children’s Hospitals
3Jan. 1, 2021 to June 30, 2021June 30, 2022July 1, 2022 to Sept. 30, 2022General Funds Phase 3Quality Incentives (Jan. – Mar.)
4July 1, 2021 to Dec. 31, 2021Dec. 31, 2022Jan. 1, 2023 to Mar. 31, 2023Unknown/TBA

HHS indicated the Provider Relief Fund reporting portal will open July 1, 2021. 

Responsibility for Reporting:

For the purposes of registration and reporting in the PRF Reporting Portal, the Reporting Entity is the entity that registers its Tax Identification Number (TIN) and reports on payments received by that TIN and/or its subsidiary TINs.

A parent entity may report on its subsidiaries’ General Distribution payments regardless of whether the subsidiary TINs received the General Distribution payments directly from HRSA or whether General Distribution payments were transferred to them by the parent entity.  However, a parent entity may not report on its subsidiaries’ Targeted Distribution payments.

Reporting Data Elements:

  1. Interest Earned on Provider Relief Funds
  2. Other Assistance Received
  3. Use of SNF and Nursing Home Infection Control Distribution Payments (if applicable)
  4. Use of General and Other Targeted Distributions
  5. Net Unreimbursed Expense Attributable to Coronavirus
  6. Lost Revenues Reimbursement

(Details on the Data Elements can be found: provider-post-payment-notice-of-reporting-requirements-june-2021.pdf (hhs.gov))

Important to note, HHS has yet to indicate or release any forms which may be required for reporting, but has indicated that additional guidance will be made available in the coming days and weeks. This means that until more guidance is posted with regards to reporting, we still cannot make definitive decisions on the next course of action for accurate reporting. Our team is carefully monitoring the HHS and HRSA websites for additional updates and will communicate that information and its implications to our clients and friends in the healthcare industry.

These reporting requirements will not apply to recipients of funds from:

Audit Requirements:

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. 

Non-for-profit organizations: There is a discrepancy between this most recent guidance and the Compliance Supplement Addendum issued by the Office of Management and Budget regarding timing for reporting the Provider Relief Funds on the Schedule of Expenditures of Federal Awards (SEFA). This most recent guidance requires the Single Audit based on the fiscal year expenditures, but the Compliance Supplement Addendum issued in December 2020 stated “For fiscal years ending (FYE) in 2020 on or before December 30, 2020, the entity reports no PRF expenditures (including no lost revenue). For a FYE December 31, 2020, the entity reports on the SEFA as expenditures (including lost revenue) based upon the PRF report for calendar year ending December 31, 2020, and discloses in the footnotes to the SEFA that the amount included on the SEFA is based upon the December 31, 2020 PRF report. For fiscal years ending in 2021 on or before June 29, 2021, the entity reports on the SEFA as expenditures (including lost revenue) based upon the PRF report for calendar year ending December 31, 2020, and discloses in the footnotes to the SEFA that the amount included on the SEFA is based upon the December 31, 2020 PRF report.”  The amount listed on the SEFA drives the Single Audit requirement. We will communicate any additional clarification regarding this timing discrepancy once additional information is issued by the regulating entities.

Commercial organizations have two options:

  1. A financial related audit of the award or awards conducted in accordance with Generally Accepted Government Auditing Standards.
  2. An audit in conformance with the requirements of a Single Audit.

Next steps:

In advance, there are steps you can take to ready your organization for the kickoff of the future reporting requirements: 

  • Establish a reporting account by registering at the newly enabled Provider Relief Funding Portal reporting website. 
    • This is a required first step for providers to fulfill their reporting requirements.
  • Carefully review the Post-Payment Notice of Reporting Requirements document to better understand the data that HHS will collect as a part of the reporting process.
  • Carefully review the FAQs: CARES Act Provider Relief Fund Frequently Asked Questions (hhs.gov)
  • Review Provider Relief Fund receipts and track by type and timeframe of receipt
    • Note those who did not receive (or receipts were less than $10,000) Provider Relief Funds during any given quarter as indicated, no reporting will be required during that time frame.
  • Review Expenses and Lost Revenue by timeframes indicated above to ensure appropriate documentation was kept before reporting is required.

Our firm’s HHS Consulting and Advisory Team is here to help you interpret the guidance and complete the application. More updates to follow in the coming weeks as further guidance is posted. To request support, please email HHSreporting@muellerprost.com.

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