HHS Releases Reporting Details (and Deadline?) For Provider Relief Fund Use
On July 21, the Department of Health & Human Services (HHS) released several details about upcoming reporting requirements applicable to Provider Relief Fund (PRF) recipients. Embedded within those appears to be the first indication of a potential deadline to use PRF funds.
Reporting Requirements
HHS indicates any recipient receiving one or more PRF payment(s) exceeding $10,000 in aggregate will be required to report on how they complied with the PRF’s terms and conditions, including allowable uses of funds. This requirement would apply to all of the PRF’s distributions, including:
- General Distribution Tranche 1, 2
- Medicaid/CHIP Distribution
- Dental Distribution
- Rural Distribution
- High Impact Area Distribution
- Skilled Nursing Facilities Distribution
- Indian Health Service Distribution
- Safety Net Hospital Distribution
It would not apply to PRF dollars used to reimburse providers for actual care and treatment for uninsured COVID patients, as those are claims-based.
HHS has not released details of the data elements for the report, but indicates guidance will be forthcoming by August, 17, 2020. In addition, the Health Resources & Services Administration will provide question and answer sessions. A new reporting portal is being created and will be live by October 1, 2020.
Reporting Deadlines, Deadline To Use PRF?
Recipients may begin reporting once the portal is open in October, but must report within 45 days of the end of calendar year 2020. Therefore, if the recipient used all of its funds prior to December 31, 2020, a a single, final report may be submitted anytime between October and February 15, 2021.
However, HHS goes on to add that if recipients have unexpended funds after December 31, 2020, then they must submit “a second and final report no later than July 31, 2021.” Since a second “and final” report is due, the July 31 date appears to establish a deadline to use all PRF dollars.
The only other mention of a timeline to use PRF dollars came in a June 22 HHS FAQ that nebulously said, “If, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses, then they will return this money to HHS.” Since this is the first time a specific date has been referenced, CLA awaits further confirmation and guidance.
Finally, we would point out that the details summarized above are different than the single or program audit requirements that apply in certain cases. [See our blog post from July 16 for details on the PRF and single audits.]
What Should You Do? CLA Can Help
For those who receive PRF distributions, here are a few tips to prepare you for these reports:
- Document, document, document everything you do related to PRF
- Categorize and track COVID expenses and lost revenues,
- Ensure you understand acceptable uses of PRF dollars,
- Review all of the terms and conditions, and
- Diligently track use of your PRF (and other COVID stimulus) funds.
Finally, reach out if CLA can assist. From our broad experience in audits, including single audits, to our COVID-specific economic stimulus funds tracking tool, we are here to help.
Jennifer Boese is the Director of Health Care Policy at CLA. She is a highly successful public policy, legislative, advocacy and political affairs leader, including working in both the state and federal government as well as the private sector. She brings over 20 years of government relations and public policy knowledge with her to CLA. Well over half of her career has been spent dedicated to health care policy and the health care industry, affording her a deep understanding of the health care market and environment, health care organizations and health care stakeholders. Her role at CLA is to provide thought leadership, policy analysis and strategic insights to health care providers across the continuum related to the industry's ongoing transformation towards value. A key focus of that work is on market innovations and emerging payment models. Her goal is to help CLA clients navigate and thrive in an increasingly dynamic health care environment.
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