HHS Releases Reporting Details (and Deadline?) For Provider Relief Fund Use

07/28/2020

By Jennifer Boese Director CliftonLarsonAllen Madison Email T. 608.662.7635

On July 21, the Department of Health & Human Services (HHS) released several details about upcoming reporting requirements applicable to Provider Relief Fund (PRF) recipients. Embedded within those appears to be the first indication of a potential deadline to use PRF funds.

Reporting Requirements

HHS indicates any recipient receiving one or more PRF payment(s) exceeding $10,000 in aggregate will be required to report on how they complied with the PRF’s terms and conditions, including allowable uses of funds. This requirement would apply to all of the PRF’s distributions, including:

  • General Distribution Tranche 1, 2
  • Medicaid/CHIP Distribution
  • Dental Distribution
  • Rural Distribution
  • High Impact Area Distribution
  • Skilled Nursing Facilities Distribution
  • Indian Health Service Distribution
  • Safety Net Hospital Distribution

It would not apply to PRF dollars used to reimburse providers for actual care and treatment for uninsured COVID patients, as those are claims-based.

HHS has not released details of the data elements for the report, but indicates guidance will be forthcoming by August, 17, 2020. In addition, the Health Resources & Services Administration will provide question and answer sessions. A new reporting portal is being created and will be live by October 1, 2020.

Reporting Deadlines, Deadline To Use PRF?

Recipients may begin reporting once the portal is open in October, but must report within 45 days of the end of calendar year 2020. Therefore, if the recipient used all of its funds prior to December 31, 2020, a a single, final report may be submitted anytime between October and February 15, 2021.

However, HHS goes on to add that if recipients have unexpended funds after December 31, 2020, then they must submit “a second and final report no later than July 31, 2021.” Since a second “and final” report is due, the July 31 date appears to establish a deadline to use all PRF dollars.