HHS Releases New Reporting Requirements for PRF Recipients

On June 11, 2021, the U.S. Department of Health and Human Services (HHS) issued a revised Post-Payment Notice of Reporting Requirements for recipients of the Provider Relief Fund (PRF). These reporting requirements only relate to the General and Targeted Distributions of this program – which includes the Skilled Nursing Facility (SNF) and Nursing Home Infection Control Distributions (including Quality Incentive Program payments).

The notice includes several key changes, including the period of availability for the use of funds, when the reporting module is set to be open, and due dates for the required reports to be submitted.

What is New?

Under the old guidance, the maximum period of availability for the use of funds was through June 30, 2021. However, under the revised guidance the deadline is based upon the date the funds were received. The new deadlines for the period of availability are as follows:

Table 1: Deadlines for Use of Funds

	Payment Received	Funds Must be Used By
Period 1	April 10, 2020 – June 30, 2020	June 30, 2021
Period 2	July 1, 2020 – December 31, 2020	December 31, 2021
Period 3	January 1, 2021 – June 30, 2021	June 30, 2022
Period 4	July 1, 2021 – December 31, 2021	December 31, 2022

Source: Health and Human Services

To align with the periods of payments received and use of funds, the reporting time periods have also changed. The requirements apply to recipients who received payments exceeding $10,000 in aggregate during any Payment Received Period. The new reporting time periods are as follows:

Table 2: Reporting Time Periods

	Payment Received	Reporting Time Period
Period 1	April 10, 2020 – June 30, 2020	July 1, 2021 – September 30, 2021
Period 2	July 1, 2020 – December 31, 2020	January 1, 2022 – March 31, 2022
Period 3	January 1, 2021 – June 30, 2021	July 1, 2022 – September 30, 2022
Period 4	July 1, 2021 – December 31, 2021	January 1, 2023 – March 31, 2023

Source: Health and Human Services

Recipients of greater than $10,000 in aggregate that do not report their use of funds in the reporting periods listed above will be considered out of compliance with the payment Terms and Conditions.

What Has Not Changed?

The Coronavirus Response and Relief Supplemental Appropriations Act required the recipient of Targeted Distributions to be the entity that would report the use of funds, regardless of whether they were transferred to another entity. In reporting these funds, the entity that received the funds discloses whether the funds were transferred to a subsidiary or stayed with the recipient.

Entities will report the use of their funds on healthcare-related expenses to the extent they were paid for with PRF distributions. Subsequently, they will report any lost revenues using either a comparison of year-over-year actual patient revenues, comparison of budgeted patient revenues to actual patient revenues, or another reasonable method for determining lost revenues.

The audit requirements for recipients are largely the same, with non-federal entities being subject to Single Audit requirements if they expend more than $750,000 in federal funds during their fiscal year. Commercial organizations that received more than $750,000 of federal funding can choose between two options: a financial related audit conducted in accordance with Generally Accepted Government Auditing Standards, or a Single Audit.

For more information about the new requirements, contact us. We are here to help.

© 2021