Healthcare Alert: Provider Relief Fund Reporting Updates Announced

On Friday, June 11, the Department of Health and Human Services (HHS) announced some changes to the Provider Relief Fund (PRF) Reporting Requirements and declined other requests for changes in a long-awaited response. Many of us were hyper focused on these reporting requirements earlier this year, and now so much time has passed, we may have forgotten what PRF means. Well, maybe not. In any event, HHS under the recent leadership of Secretary Xavier Becerra, released new and somewhat relaxed guidance on reporting timeline obligations.

Many health care providers struggled to spend their PRF funds in the timeline allotted which is coming up in a few weeks on June 30, 2021. Recall that there are only so many expenses for which a provider may use the PRF, and they are all tied to prevention, preparation for, and response to the coronavirus. Thus, some provider advocates urged the HHS to allow providers more time to expend their funds which it declined to do overall. However, HHS did set up new deadlines that correlate with the timing of the receipt of the PRF. For example, providers who received funds between July 1 – December 31, 2020 must expend funds by December 31, 2021. (The payment date is determined by the date of deposit into your automated clearinghouse (ACH) account.) In other words, this is one year from the latest date in that range. However, it remains to be seen whether these revisions will be helpful for the majority of health care providers. Many providers stopped applying for additional rounds of funding when they realized they were having difficulty expending what they had. This result is either an indication that providers did not sustain significant losses or just did so in such a way that the PRF could not resolve.  
 

The below shows the new deadlines for both the use of funds and corresponding reporting period, which is available on the Provider Relief Fund Reporting Portal: 
 

 

 

In addition to the reporting timeline requirements, HHS also now requires providers to report for each payment they received in excess of $10,000 rather than the cumulative greater-than-$10,000-requirement which required only one report according to earlier guidance. Additionally, the agency now requires skilled nursing facilities that received the Skilled Nursing Facilities and Nursing Home Infection Control Distribution to report along with the General and Targeted Distribution groups. 
 

The PRF portal has been open for registration only since the early part of 2021 while we awaited guidance on the reporting requirements and anticipated changes. Now the portal will be open for actual reporting beginning July 1, 2021. The Reporting and Auditing requirements are available here. Providers are encouraged to register if they have not done so already and then dust off their accounting reports in preparation for submission on July 1, 2021. If you need assistance in preparing your reports, consider reaching out to your accountant and one of our health care attorneys at Brouse McDowell for guidance.