Healthcare providers and facilities that received more than $10,000 in COVID-19 Provider Relief Funds (PRF) will need to report how they used the money through a new reporting system that will open on January 15, 2021. The Department of Health and Human Services (HHS) finally released the six-page guidance on September 19, 2020, after several earlier delays.
Who Should Report
Provider Relief Funds were appropriated early on during the COVID-19 public health emergency through two emergency spending bills, namely the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Paycheck Protection Program (PPP) and Health Care Enhancement Act. The funds were made available to eligible healthcare providers for healthcare related expenses or lost revenues attributable to the coronavirus.
Recipients of these funds agreed to Terms & Conditions, which require compliance with reporting requirements as specified by the Secretary of Health and Human Services in program instructions.
The reporting requirements do not apply, however, to the following recipients of Provider Relief Funds:
- Nursing Home Infection Control distribution recipients
- Rural Health Clinic Testing distribution recipients
- Health Resources and Services Administration (HRSA) Uninsured Program reimbursement recipients
What To Report
The new guidance specifies what information will need to be reported, along with specific data items each provider will need to supply. Generally, providers will report healthcare-related expenses attributable to COVID-19 that have not or will not be reimbursed by other sources along with PRF payment amounts not fully expended on healthcare-related expenses that will be applied to lost revenues because of COVID-19.
If recipients do not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to COVID-19, or to apply toward lost revenues.
Guidelines Vary by Amounts Received
Providers who received between $10,000 and $499,999 will report their healthcare-related expenses in high-level categories of a.) General and Administrative (G&A) and b.) other healthcare-related operating expenses.
Recipients who received $500,000 or more in PRF payments are required to report healthcare-related expenses according to detailed segments within the two categories. For instance, G&A healthcare-related expenses are broken down into the following:
- Fringe Benefits
- Lease Payments
- Other General and Administrative Expenses.
Whereas, other healthcare-related operating expenses including the following:
- Information Technology (IT)
- Other Healthcare-Related Expenses
When to Report
Providers will need to submit their initial reports by February 15, 2021. Providers who do not fully expend PRF funds prior to December 31, 2020, will have until July 31, 2021, to complete their final reporting.
For more information about the recently released reporting requirements, check out these resources:
- HHS’ Cares Act Provider Relief Fund Reporting Requirements and Auditing webpage
- HHS’ Recent Notice: “General and Targeted Distribution Post-Payment Notice of Reporting Requirements”
The reporting guidance from HHS also reminded providers that reporting entities that expended $750,000 or more in aggregated federal financial assistance in 2020 (including PRF payments and other federal financial assistance) are subject to Single Audit requirements. To learn more about these audits, check out this article from Certified Public Accountants Katz Sapper & Miller, “Provider Relief Funds Received Under the CARES Act Impose Audit Requirements.”
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