Updated Reporting Requirements for Provider Relief Funds

The Provider Relief Fund (“PRF”) was established to support healthcare providers, hospitals, physicians, skilled nursing facilities and other eligible healthcare providers in the battle against COVID-19.  The purpose of the PRF is to reimburse providers for healthcare related expenses and lost revenues attributable to the pandemic.

Many providers received an initial, unsolicited PRF disbursement in April of 2020.  In total, general distributions were paid out in three Phases over the course of 2020 based on various criteria for each phase.  Distributions are not required to be repaid as long as providers comply with the terms and conditions set forth by the Department of Health and Human Services (“HHS”).

Importantly, providers that received one or more payments exceeding $10,000 in the aggregate in PRF funds will be required to file online reports regarding usage of the funds.

We have been awaiting guidance from the HHS on the reporting requirements for the PRF funds received, and just received that information on June 11, 2021.

New Update

The HHS just issued updated reporting requirements for recipients who received one or more payments exceeding $10,000 in the aggregate rather than $10,000 cumulatively. The updated deadlines establish dates for the usage of funds based upon receipt of the funds, and an expanded schedule for the reporting time periods (also based upon the receipt of the funds).

The new guidance states:

  • Recipients will now have a 90-day period to complete reporting rather than the initial 30-day reporting period.
  • The reporting requirements are now applicable to recipients of the Skilled Nursing Facilities and Nursing Home Infection Control Distribution, in addition to the General and Targeted Distributions.
  • The PRF Reporting Portal will open for providers to begin submitting their information on July 1, 2021.

Important Deadline and Reminders

The PRF states that the relief fund payments will be used to prevent, prepare for and respond to the coronavirus and shall reimburse the recipients only for healthcare expenses and lost revenue attributable to the coronavirus.

Providers that have not yet used all PRF monies to cover qualifying increased costs or lost revenues as of December 31, 2020, may continue to use their funds for those purposes through the dates reflected on the updated summary of reporting requirements illustrated in Table 3.  Under current HHS guidance, any funds that are not used for qualifying purposes will need to be returned after June 30, 2021.

For additional information on the PRF terms and conditions, reporting requirements, expense requirements, calculation of lost revenues or more, feel free to reach out to Sax’s Healthcare Practice for proper guidance with respect to your unique set of circumstances.

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