HHS Funds Distribution Requirements

Insights Client Alert

The Department of Health and Human Services (HHS) has distributed a significant portion of the $100 billion appropriated in the CARES Act for the Provider Relief Fund. This has been or will be awarded in several different distribution fund types:  $30 billion general; $20 billion general; $10 billion rural; $12 billion high impact; and uninsured.

Each distribution has attestation and/or compliance requirements.  The attestation involves accepting the funds and agreeing to the terms and conditions of the distribution.  Each distribution’s terms and conditions can be found here.  HHS recently extended the attestation deadline to 45 days after the receipt of funds.  After reviewing the terms and conditions associated, we encourage providers to attest as soon as possible for each distribution they have received via the CARES Payment Attestation Portal.

On April 24th, some providers received payments based on the revenue data they submitted in their CMS cost reports. Providers without adequate cost report data on file will need to submit their revenue information to the General Distribution Portal in order to receive additional general distribution funds.  Providers who received funds automatically will still need to submit their revenue information to the General Distribution Portal so that it may be verified.  They will need to submit the following:

  • a provider’s “Gross Receipts or Sales” or “Program Service Revenue” as submitted on its federal income tax return or reported in their audited financial statements if they do not file a tax return
  • the provider’s estimated revenue losses in March 2020 and April 2020 due to COVID-19
  • a copy of the provider’s most recently filed federal income tax return or audited financial statements supporting the amounts in item 1 above

If you have any questions on how to calculate estimated revenue losses, please reach out to us to discuss further.  Providers are encouraged to complete this action as soon as possible as it could impact future distributions.

At Draffin Tucker, we are committed to providing our clients with the latest information related to COVID-19.  Please do not hesitate to contact us with any questions or concerns.  Visit our COVID-19 webpage for more information and updates.

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