What not-for-profit healthcare entities should know about Provider Relief Fund use, reporting, and more

Your organization may have been fortunate in receiving an influx of funding from several federal stimulus sources in response to COVID-19, such as HHS Provider Relief Funds and COVID-19 Uninsured Program Portal funding. While this additional support provides a substantial benefit to helping your organization maintain capacity through any future COVID-19-related impacts to business, it also comes with terms, conditions, and other regulatory requirements that must be followed. Keep these considerations in mind as you use these additional funding sources:

1. Be sure that your organization is clear on the spending timelines and reporting requirements for the usage of funds.

Provider Relief Fund guidance was updated as of Jan. 15, 2021, and the Provider Relief Fund Reporting Portal was opened for registration. All entities that have received $10,001 or more in the aggregate must register in this portal. Currently, there is no deadline that HHS has mandated for completing this registration. PRF recipients will receive an email notification about when they should complete the submission of the required reporting information on the usage of the funds. Registration should be completed as soon as possible to ensure that timely communication is received from HHS. Providers will have an additional opportunity to report by July 31, 2021, on the usage of funds not expended prior to Dec. 31, 2020. The Jan. 15 update to the Post-Payment Notice of Reporting Requirements included additional guidance as to reporting on expenses attributable to COVID-19 and lost revenues. Provider Relief Fund FAQs are posted frequently; be sure to check the HHS website for updates on a regular basis. 

2. Have you implemented sufficient procedures for tracking use of funds?

The use of all funding streams will need to be diligently documented so that when reporting on use of funds, you will be able to clearly show that multiple funding streams were not being used for the same expenses – that you didn’t engage in any “double-dipping.” This will also facilitate the reporting that will ultimately have to be done for all funding streams to confirm that you have used funding aligned with the terms and conditions on usage. Expenses charged to each funding source should be clearly documented in the accounting records to stand up to audit.

3. Have you strategically planned how you are going to prioritize use of various funding streams?

Each federal funding stream received in response to COVID-19 has different permissible uses for funds and timelines during which funds can be spent. Have you examined your operating expenses since the pandemic hit or projected continued impact from COVID-19 to determine how best to allocate funds? Are you prioritizing fund use from the sources that are most restrictive, and with the shortest timeframe during which to spend down funds, to those that are least restrictive, so that you can make sure you have additional support available in the event of a second or third wave of COVID-19 impact to your organization?

4. Have you considered Uniform Guidance Single Audit implications?

Provider Relief Fund General and Targeted Distribution payments (CFDA 93.498) and COVID-19 Testing for the Uninsured reimbursement payments (CFDA 93.461) are also federal awards and subject to Single Audit. Subparts B (General Provisions), D (Post Federal Award Requirements), E (Cost Principles), and F (Audit Requirements) of the Uniform Guidance apply to Provider Relief Funds. In accordance with the provisions of 2 CFR 200, Subpart F - Audit Requirements, nonfederal entities that expend financial assistance of $750,000 or more in federal awards in a fiscal year are required to have a single or a program-specific audit conducted for that year. Provider Relief Funds are subject to certain compliance requirements as identified in the Office of Management and Budget (OMB) 2020 Compliance Supplement Addendum. HHS will be releasing guidance at a later date with instructions as how to prepare the Provider Relief Fund Report, which will identify the amount of Provider Relief Funds earned and be the source of information that will be required to be disclosed on the Schedule of Expenditures of Federal Awards (SEFA) in relation to the Single Audit Report.