At long last, the Department of Health and Human Resources published the reporting requirements for recipients of the Provider Relief Fund (PRF). This release offers healthcare providers much-needed guidance on what kinds of documentation they need in the event of a PRF audit as well as general reporting purposes.
To Whom Will New Guidance Apply?
If your healthcare organization received total payments from the fund exceeding $10,000, these new documentation guidelines apply to you with three primary exceptions:
- Nursing Home Infection Control
- Rural Health Clinic Testing
- Health Resources and Services Administration Uninsured Program Reimbursement
August guidance from HHS stated you would need to report expenditures through the end of this year no later than February 15th, 2021 and that you may begin reporting when the portal became available. The portal was originally scheduled to open on January 15th, 2021, but the notice has since been updated to say that it is live as of Oct 1 2020 for those who prefer to get a head-start on the reporting process.
Provider Relief Fund (PRF) Guidance Highlights
HHS has created a handy visual summary of their guidance, which includes key takeaways and reminders. While it’s not an alternative to the more detailed guidance, you will find it very useful once you have read the complete HHS guidance here.
Here are some key highlights we’d like to mention.
- Calculation of Lost Revenue – The calculation of lost revenues caused by COVID-19 has changed significantly as COVID-19 has evolved over the past several months. For this reason, we advise you to review it in its entirety sooner rather than later to ensure you can comply with PRF documentation requirements to avoid surprises.
- Reporting of Eligible Expenses – Some recipients of PRF funds will be required to provide more documentation than others. As a general rule, if your organization received/spent a higher amount of total funds, expect that your reporting requirements will be greater.
- Reporting Entity – The guidance shares specifically who is required to submit reporting. This will generally be the organization that actually received the funds.
- Audits for Certain Recipients – Those who spent $750,000 or more in PRF funds and other federal aid will be subject to Single Audit requirements as outlined in 45 C.F.R § 75.501.
If you have questions regarding reporting requirements or feel like you might need assistance with these reporting requirements for Provider Relief Fund (PRF), please reach out to KHA to schedule an appointment.