Be aware of revised Provider Relief Fund reporting requirements and timing

On June 11, 2021,  the U.S. Department of Health and Human Services (HHS) released a revised Post-Payment Notice of Reporting Requirements for Provider Relief Fund (PRF) recipients. This notice supersedes the previous notice issued on Jan. 15, 2021. 

We will be hosting a webinar on August 11 to go over the notice’s highlights and changes, as well as provide an overview of the Provider Relief Fund Reporting Portal, which is slated to open for Period 1 on July 1. Register now to attend.

In the meantime, here are some key highlights to be aware of:

• The reporting requirements in the notice apply to PRF General and Targeted Distributions (including, as of this notice, the Skilled Nursing Facility (SNF) and Nursing Home Infection Control Distribution).
• The period of availability of funds is now based on the date the PRF payments were received. See chart below:

• “Recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are now required to report in each applicable Reporting Time Period” as per above, the Notice states.
• Recipients will now have 90 days to complete reporting. (Previously it was only going to be a 30-day period.)

In addition, we noted the following:

• Additional steps for reporting use of funds
• Updated examples of eligible PRF expenditures 
• Modified definition of “Patient Care Revenue” as factored into the “Lost Revenue” calculation
• Additional Frequently Asked Questions (FAQs) on use of PRF funds
• New section of FAQs addressing the calculation of Eligible Expenses and Lost Revenue
• Introduction of additional data elements to be included in the report submission
• Single Audit requirements confirmed for non-federal entities who expend $750,000 or more in federal funds during their fiscal year
  • Commercial organizations receiving $750,000 still have two options: Single Audit or Generally Accepted Government Auditing Standards (GAGAS)
• FAQ posted on the HHS website as of July 15, 2021, points out that non-federal entities will first include Provider Relief Fund expenditures and/or lost revenues on their Schedule of Expenditures of Federal Awards for the fiscal year ending on or after June 30, 2021. The FAQ also points to the forthcoming 2021 Compliance Supplement for guidance for auditors as it relates to testing the PRF program. Timing of the 2021 Compliance Supplement is unknown at this time.