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Reporting Requirements Changed Yet Again for Recipients of Provider Relief Funds

Provider Relief Funds

The U.S. Department of Health and Human Services (HHS) once again revised the reporting requirements for recipients of provider relief funds (PRF). In a notice it released on June 11, 2021, the HHS announced three major changes to the PRF program:

  1. The deadline for expending PRF payments has been extended.
  2. Providers have been given more time to file informational reports.
  3. Some of the reporting burdens for smaller providers have been lifted.

These changes are effective immediately. To better understand how this will affect your organization, let’s dig a bit deeper into each change.

1. Extending the Deadline for Expending PRF Payments

The HHS extended the deadline providers were given to spend, use, or apply their PRF payments. Under prior guidelines, all PRF funds must have been used by June 30, 2021, regardless of when the funds were received. Under new guidelines, recipients are given a minimum of 12 months from the time they received the funds to use them, up to a maximum of 18 months.

Payment Received Period OLD Deadline to Expend Funds NEW Deadline to Expend Funds
Apr. 10, 2020 – June 30, 2020
June 30, 2021
June 30, 2021
June 1, 2020 – Dec. 31, 2020
June 30, 2021
Dec. 31, 2021
Jan. 1, 2021 – June 30, 2021
June 30, 2021
June 30, 2022
July 1, 2021 – Dec. 31, 2021
N/A
Dec. 31, 2022

As a reminder, PRF recipients can only use funds to pay for eligible expenses, which might include:
Supplies and equipment to provide healthcare services to

  • COVID-19 patients
  • Workforce costs
  • Staffing and developing emergency treatment, vaccination, or testing centers
  • Costs to expand or preserve level of patient care
  • Administrative expenses
  • Other costs of services rendered
  • Lost revenues attributable to COVID-19

2. Expanding the Time Providers are Given to Report Information

Under prior guidelines, PRF recipients who were awarded at least $10,000 were required to file their post-payment reports 30 days following the deadline to use the funds. This reporting period has been expanded to 90 days.

Payment Received Period OLD reporting Period NEW Reporting Period
Apr. 10, 2020 – June 30, 2020
July 1, 2021 – July 31, 2021
July 1, 2021 – Sept. 30, 2021
June 1, 2020 – Dec. 31, 2020
July 1, 2021 – July 31, 2021
Jan. 1, 2022 – Mar. 31, 2022
Jan. 1, 2021 – June 30, 2021
July 1, 2021 – July 31, 2021
July 1, 2022 – Sept. 30, 2022
July 1, 2021 – Dec. 31, 2021
N/A
Jan. 1, 2023 – March 31, 2023

This post-payment reporting process requires PRF recipients to submit some (or all) the following information, in this order:

  1. Interest earned on PRF funds
    If your organization held PRF funds in an interest-bearing account, you must report the interest you earned on those funds.
  2. Other assistance received
    This might include SBA loans, PPP loans, FEMA assistance, local assistance, insurance proceeds, etc.
  3. Use of Nursing Home Control Distribution Payments (if applicable)
    If you received any of these payments, you must report qualifying expenses that have not been reimbursed or are not obligated to be reimbursed.
  4. Use of General and Other Targeted Distribution Payments
    Like with the Nursing Home Control Distribution Payments, PRF payments will not cover expenses that have been reimbursed or are obligated to be reimbursed.
  5. Net unreimbursed expenses attributable to COVID-19
    Entities must break out their net unreimbursed expenses into two categories: (1) general and administrative, and (2) other healthcare related. If your entity received $500,000 or more in PRF payments, you must break down those costs even further, as explained in this HHS release.
  6. Lost patient care revenues attributable to COVID-19
    If you have PRF funds remaining after paying for healthcare-related expenses, you can apply the excess to lost patient care revenues. We discuss how to calculate lost patient care revenues in this article.

Reports should also include the following identifying information about your entity:

  • Demographic information about your entity
  • Your taxpayer identification number (TIN) and potentially your national provider identifier (NPI)
  • Your entity’s fiscal year-end date
  • Your entity’s federal tax classification – sole proprietor, partnership, S corporation, C corporation, nonprofit, etc.
  • Personnel, patient, and facility metrics
  • Changes in entity ownership (if any)

3. Lifting Reporting Burdens for Smaller Providers

And finally, the HSS eliminated reporting burdens for small providers. Only those who received $10,000 in PRF payments in any single payment period will be required to report their usage of those funds. Smaller providers that were awarded $10,000 in aggregate over multiple payment periods will not need to follow the strict reporting requirements listed above.

Prepare for Post-Payment Reports Now

For those who received PRF payments in 2020 or early 2021, your reporting period is approaching. Be prepared with the information we discussed above. If you haven’t done so already, you can register your entity with the PRF Reporting Portal, which is now up and running. If you have any questions about PRF reporting requirements or any other matter pertaining to PRF payments, please contact a professional in LaPorte’s Healthcare Industry Group.