On July 20th, 2020, the Department of Health and Human Services (HHS) announced an update to the reporting requirements for healthcare providers who received funds through any of the distributions of the Provider Relief Fund (PRF). As previously reported by WebsterRogers, HHS has already delayed their initial requirement of providers submitting quarterly reports detailing their expenditures related to the funds distributed to them. That deadline would have required providers to submit their reports no later than July 10th, 2020. In the most recent updates by HHS on July 20th, 2020, HHS has further delayed this reporting requirement, but has given some guidance on what to expect.

• By August 17th, 2020 HHS expects to release detailed instructions regarding the reporting system and format, to include reporting requirements and data collection template.
• The threshold for providers who are required to submit their reports has been set to $10,000 in funds received through any of the distributions of the PRF. These would include the general funds, additional funds, Medicaid, CHIP and/or Targeted funds.
• The reporting system will become available to recipients of the PRF for reporting beginning on October 1st, 2020.
• All reports must be submitted by February 15th, 2021 for the reporting period ending on December 31st, 2020.
• Providers who have expended all of their received funds before December 31st, 2020 can submit a single, final report at any time between October 1st, 2020 but no later than February 15th, 2021.
• Those providers who have NOT expended all of their received funds by December 31st, 2020 must submit a second and final report no later than July 31st, 2021.
• As a reminder, all providers that received HHS Provider Relief Funds should adopt a policy as part of its financial procedures, record keeping and compliance program to proactively demonstrate compliance with federal requirements 45 C.F.R. §75.302 and 75.361-365 as well as the applicable Terms and Conditions by HHS.

In summary, if you have received more than $10,000 through any combination of the PRF distributions, you will be required to submit expenditure reports to HHS. As always, WebsterRogers is here to help you navigate these requirements and other needs impacting your operations.  Our team of healthcare accounting and consulting experts can assist with your questions related to the Provider Relief Funds, Paycheck Protection Program, and other requirements.

Contact our Healthcare Services Team for more information or to get assistance: healthcare@websterrogers.com.