Health care providers have dedicated their resources to providing patients with the care they need throughout a rapidly evolving pandemic. During these unprecedented times, medical providers have been faced with additional costs related to treating coronavirus patients as well as lost revenues due to government shutdowns and the suspension of elective procedures. To help mitigate the financial impact on providers, the U.S. Department of Health and Human Services (HHS) issued Provider Relief Fund (PRF) payments to be used towards eligible coronavirus related expenses and to help cover lost revenues.
Recipients of these funds agreed to certain terms and conditions, including reporting requirements pertaining to the use of these funds. If in any Payment Received Period you received one or more payments totaling $10,000 or more in the aggregate, you are subject to the reporting requirements. Failure to meet these requirements could result in HHS seeking recoupment of the funds. The following table provided by HHS summarizes each Payment Received Period, along with the Deadline to Use the Funds and the respective Reporting Time Period:
Summary of Reporting Requirements
*On September 10, 2021, HHS offered a 60-day grace period for Period 1. Although the reporting time period and deadline to use the funds has remained the same, HHS will not initiate collection procedures during this grace period.
Providers will be required to report on eligible coronavirus related expenses, such as personal protective equipment, tele-health costs, touch-free technology, hazard pay to employees, physical barriers meant to reduce the spread of COVID-19, and costs related to COVID testing to name a few. The expenses need to be for the preparation for, prevention of or response to coronavirus. Additionally, if you received any other funds, either from federal, state, or local governments or from business insurance, those monies need to be reported and applied against the eligible expenses first. If you have not used all the PRF payments for eligible expenses, you will need to provide information on lost revenues attributable to coronavirus. HHS is allowing several different methods to report on lost revenues.
Additional reporting requirements will include interest earned on the funds if they were held in an interest-bearing account, metrics related to personnel, patients and facilities and you will need to answer various questions about the impact of the payments during the period of availability. Providers that expend $750,000 or more in federal funds, including the PRF payments, are subject to a Single Audit requirement.
The reporting requirements outlined above are a general overview of the complex calculations and reporting required to comply with HHS guidelines. For additional information and guidance related to the Provider Relief Fund payments and the related reporting requirements, click here. If you would like assistance or advice regarding your reporting obligations, please call us at 401-921-2000, or complete our online contact form.