HHS Updates Guidance and Filing Dates for Provider Relief Fund
The Department of Health and Human Services (HHS) has updated the Provider Relief Fund (PRF) reporting requirements and FAQs, establishing new deadlines for the use of funds based on the date the payment was received, extending the time period for recipients to report on the use of PRF payments, and requiring recipients of the Skilled Nursing Facility and Nursing Home Infection Control Distribution to report on the use of PRF payments. The updates extend the deadline for recipients to use PRF payments, but only for those payments received after June 30, 2020, and now give recipients 90 days to complete reporting on the use of PRF payments. The FAQs also further clarify expenses eligible and attributable to COVID-19.
Payment Received Periods
The updated guidance establishes new “Payment Received Periods” in which the date PRF payments were received by a recipient establishes both (1) the time period in which the PRF payments can be used (“period of availability”) and (2) the deadline for reporting on the use of those funds. For payments received prior to June 30, 2020, which generally encompass the PRF payments made in Phase 1, the period of availability for the use of funds is limited to the period between the date the funds were received and June 30, 2021.
Providers are required to follow their normal basis of accounting (now clarified as either cash or accrual) for determining the date the expense is incurred. For PRF payments received prior to June 30, 2020, this requirement prohibits PRF recipients from using payments for expenses or lost revenue occurring after June 30, 2021 and requires that any remaining payments that have not been spent on eligible expenses or lost revenue incurred prior to June 30, 2021 be returned to HHS by September 30.
Recipients are now required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments). Recipients that do not report within the applicable Reporting Time Period will be considered out of compliance with payment Terms and Conditions, and the relevant PRF payments may be subject to recoupment. Under the new requirements, recipients who received multiple PRF payments that occurred in different Payment Received Periods will be required to submit reports for each applicable reporting time period; the new requirements limit the ability of recipients who have used all of the PRF payments they received from submitting a single report in the July–September 2021 reporting period.
Summary of Reporting Requirements
|Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)||Deadline to Use Funds||Reporting Time Period|
|Period 1||From April 10, 2020 to June 30, 2020||June 30, 2021||July 1 to September 30, 2021|
|Period 2||From July 1, 2020 to December 31, 2020||December 31, 2021||January 1 to March 31, 2022|
|Period 3||From January 1, 2021 to June 30, 2021||June 30, 2022||July 1 to September 30, 2022|
|Period 4||From July 1, 2021 to December 31, 2021||December 31, 2022||January 1 to March 31, 2023|
These reporting requirements do not apply to the Rural Health Clinic COVID-19 Testing Program nor the two claims reimbursements programs: the HRSA COVID-19 Uninsured Program and the HRSA COVID-19 Coverage Assistance Fund.
In addition to including new information on reporting and reporting data elements, the updated guidance contains a revision on reporting lost revenues attributable to COVID-19. Under the updated guidance, recipients using PRF payments for lost revenues will provide information used to calculate lost revenues attributable to COVID-19 depending on the method they choose: (i) the difference between actual patient care revenues, (ii) the difference between budgeted (prior to March 27, 2020) and actual patient care revenues, or (iii) another method of estimating revenues. For options (i) and (ii), HHS revised the previous requirement that recipients submit revenues/net charges from patient care for 2020, and now requires that recipients submit revenues/net charges from patient care by payer mix by quarter for each quarter during the period of availability.
The PRF reporting portal will open for recipients on July 1, 2021, and all recipients that received a PRF payment between April 10, 2020, and June 30, 2020 (now identified as Period 1) will be required to submit a report on the use of funds received in Period 1 and return any unused funds by September 30, 2021. HHS is encouraging recipients to complete their user registrations in advance of the portal opening and anticipates issuing a “comprehensive user guide” and supporting worksheets to assist recipients with the reporting requirements.