HHS Provider Relief Funds Reporting Requirements

InsightsClient Alert

The Department of Health and Human Services (HHS) has released the new reporting requirements for providers that received more than $10,000 in Provider Relief Funds.  This dollar limit is applied in the aggregate for all the distributions from the Provider Relief Fund (i.e. General, High Impact, Safety Net, Rural, and others) and not to each distribution.

These reporting requirements do not apply to the Nursing Home Infection Control distribution or the Rural Health Clinic Testing distribution.  Separate reporting requirements will be announced for these distributions.  These reporting requirements also do not apply to reimbursement from the Health Resources and Services Administration (HRSA) Uninsured Program.  Additional reporting may be announced in the future for these payments.

Information on the newly released reporting requirements can be found here.  We strongly encourage you to review this information and consider the impact to your organization as there are significant changes from previously released guidance and FAQs.  Additional information is expected to be issued in the future.

HRSA plans to offer Question & Answer Sessions via webinar in advance of the reporting deadline, and as needed, HRSA will also issue Frequently Asked Questions to aid in the reporting process.

Providers will report on how the funds received have been expended by utilizing a system that is expected to be available in early 2021.

Reporting requirements include submission of:

  • Quarterly data for calendar years 2019 and 2020
  • Healthcare related expenses and lost revenues attributable to coronavirus
  • Net patient service revenues by defined payer categories
  • Expenses by defined categories and subcategories
  • Assistance received from federal, state, local, business insurance, and other
  • Personnel, patient, and facility metrics
  • Change in ownership disclosures
  • Single audit matters

As described in the Post Payment Notice of Reporting Requirements dated September 19, 2020, providers will provide information on expenses attributable to coronavirus not reimbursed by other sources and data to calculate “lost revenues attributable to coronavirus, represented as a negative change in year-over-year net operating income from patient care related sources. Once revenue information is provided, cost/expense impacts will be calculated based upon a calendar year comparison of 2019 to 2020 healthcare expenses to determine net operating income.”

Providers with over $10,000 of payments must submit the first report for the period ending December 31, 2020 by February 15, 2021.   Providers with unexpended funds on December 31, 2020 must submit a second and final report no later than July 31, 2021 for the time period January 1, 2020 – June 30, 2021.

In addition to this newly released reporting process, there are also single audit requirements to be considered.

For more information, please contact our Albany office at (229) 883-7878 or our Atlanta office at (404) 220-8494.

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