Provider post-payment notice of reporting requirements update

Has your organization received funding from the Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Fund (PRF)? If you answered no, you may want to check again. You could have received funding without realizing it. This new reporting will allow providers to demonstrate compliance with the terms and conditions related to the funding distributions received. We encourage all entities, including “nontraditional” healthcare organizations, governmental entities, and nonprofits to determine whether they have received PRF funding and then to understand the reporting or other requirements of it. Here’s what to do:

Step one: Confirm the receipt of PRF funding

The first step, recognizing the receipt of PRF funding, has recently been made a bit easier by publicly available tools that show listings of the organizations that received funding from several HHS distributions, such as:

• Medicare General Distribution
• Medicaid General Distribution
• CHIP & dental General Distribution
• Targeted allocations to high-impact areas
• Targeted allocations to safety net hospitals
• Targeted allocations to rural providers
• Targeted allocations to tribal facilities
• Targeted allocations to clinics and urban health centers
• Targeted allocations to skilled nursing facilities

One data set, available at the HHS website and regularly updated, shows the list of providers who have attested to receiving one or more payments and agreed to the terms and conditions. In addition, this site has information on other COVID-19 funding amounts distributed outside of the PRF.

Step two: Figure out the reporting requirements for PRF funding

The next thing organizations need to consider are the reporting requirements. One of these requirements was announced on July 20, 2020. The HHS stated that it will require separate reporting for each organization that received PRF amounts. This reporting is applicable to any entity that received funding from the CARES Act PRF distributions listed below:

General distributions:

• Initial Medicare distribution
• Additional Medicare distribution
• Medicaid, dental, & CHIP distribution

Targeted distributions:

• High-impact area distribution
• Rural distribution
• Skilled nursing facilities distribution
• Indian health service distribution
• Safety net hospital distribution

The new HHS reporting requirements will be due by Feb. 15, 2021, for funds expended through Dec. 31, 2020. For those expended after Dec. 31, 2020, the report due date is July 31, 2021. Additional information on reporting procedures and the format to be used is expected sometime in August 2020. A question and answer session will be conducted by the Health Resources and Services Administration (HRSA) prior to the submission deadlines. Note that these new reporting requirements must be met in addition to any audit requirement that may be applicable due to funding received.

Have questions about your PRF funding, CARES Act funding, or other grant-related questions? Please contact us! We’re happy to help.