Reingruber Alert: Final Provider Relief Fund Reporting Requirements Are Here

6/17/2021 - By Claudia Reingruber, CPA, CHC

HHS Issues New Instructions on June 11, 2021

  • These new reporting instructions supersede all prior reporting instructions
  • FAQs regarding PRF reporting have also been updated

Elements of the New PRF Reporting Instructions

  • Four time periods have been defined for:
    • Identifying PRF payments received in each period; and
    • Reporting respective fund use for each period
  • Each of the four time periods has its own unique 90-day reporting window
  • Recipients of > $10,000 in a time period must report for that time period
  • PRF General and Targeted Distributions must be reported 
    • SNF and Nursing Home Infection Control Distributions (including QIP Incentives) are considered Targeted Distributions
  • These requirements do not apply to:
    • RHC COVID-19 Testing Program or 
    • Claims reimbursements from HRSA’s Uninsured Program or Coverage Assistance Funds

Summary of Reporting Requirements

 

Key Updates in New Notice of Reporting Requirements

  • Ability to use PRF payments is based on date received
  • Reporting is required for each period in which >$10,000 was received
  • Extends the deadline for PRF use for funds received on or after 07/01/2020
    • Recipients will now have at least 12 months to use funds from receipt date
  • Reports for each period will be due 90 days after the deadline to use funds  
  • Recipients of SNF and NH Infection Control Distribution, including QIPs, are now required to report through the portal 
  • Notice defines the order in which data will be reported
  • Recipients of >$499,999 of PRF payments in a “Payment Received Period” will have more detailed reporting obligations
  • The new General and Targeted Distribution Post-Payment Notice of Reporting Requirements as of 06/11/2021 can be accessed here
  • Updated CARES Act PRF FAQs can be accessed here 
  • The PRF Reporting Portal will open for submission of data on 07/01/2021
  • If you have not yet registered in the PRF Reporting Portal, do so now!
  • PRF Reporting Portal and instructions can be found here 

The Healthcare Division at Saltmarsh can help: 

  • Reevaluate reporting obligations based on new instructions
  • Help comply with initial reporting period deadline of 09/30/2021
  • Ensure optimal reporting and PRF use for each “Payment Received Period”
  • Ensure all COVID expenses are identified and properly determined
  • Evaluate options for “Lost Revenue” calculations per instructions
  • Assess compliance with the Terms and Conditions for each PRF payment
  • Prepare for potential audits of PRF fund use
  • Make sure you understand the changes in these Final Reporting Requirements

For questions or more information, please contact our Healthcare team, and join our email list!

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