After much delay and waiting on the part of providers who received funding, on June 11, 2021, the Department of Health and Human Services (HHS) released updated reporting requirements, and related deadlines, for recipients of Provider Relief Fund (PRF) payments.

PRF recipients must use the funds for eligible expenses to prevent, prepare for, and respond to coronavirus, and/or for lost revenues attributable to coronavirus. Recipients are required to maintain adequate documentation to substantiate that these funds were used for healthcare related expenses or lost revenues attributable to coronavirus, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them. The burden of proof is on the recipient to ensure that adequate documentation is maintained.

The deadline to use the funds depends on the date the funds were received, as shown in Table 1:

Table 1: Deadlines for Use of Funds

Recipients who received more than $10,000 in PRF funds in total during a payment received period are required to report how the funds were used within the applicable reporting time period, as indicated in Table 2:

Table 2: Reporting Time Periods

Reporting is to be done through an online portal operated by HHS. This requires reporting costs by categories defined by HHS, as well as reporting revenue by source (Medicare, Medicaid, commercial insurance, etc.), along with other requirements.

An important note: Most recipients that expend a total of $750,000 or more in federal funds during their fiscal year are subject to Single Audit requirements in accordance with Generally Accepted Government Auditing Standards (GAGAS). Commercial organizations have the option to receive a financial related audit of the award or awards conducted in accordance with GAGAS in lieu of a single audit.  Both options will require recipient entities to hire an auditor to perform an audit in accordance with GAGAS.

For more information, you can access a copy of the new requirements here: PRF Reporting Requirements June 11, 2021; and view FAQs here: PRF Frequently Asked Questions. 

^{Readers should not act upon information presented without individual professional consultation.}

^{Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.}