Truly a relief in 2020, the federal government allocated $175 billion in payments to be distributed to providers of healthcare services and support through the Provider Relief Fund (PRF). Providers even received the Relief Fund Payments from Phase 1, the $30 Billion General Distribution, automatically. In addition to the General Distribution, various other PRF distributions were Select Targeted Distributions.
Provider Relief Fund payments were issued for healthcare-related expenses or lost revenue due to preventing, preparing for, or responding to Covid-19. Separately, the COVID029 Uninsured Program was to reimburse providers for testing and treating uninsured individuals with COVID-19.
With 2020 behind us in a blur, the question arises, “Are these distributions required to be repaid to the US government?” Many providers are thankful the answer to that question can be “no.” However, the providers must comply with the terms and conditions* associated with the distribution received, including the reporting requirements therein. Examples of information recipients may be required to report include revenue/net charges from patient care, revenue by patient care payor mix, and general and administrative and healthcare related expenses attributable to coronavirus. For recipients of over $500,000 in aggregate PRF payments, providers must provide a further expense breakdown that includes mortgage/rent, personnel, utilities, supplies, equipment, and other high-level expense categories. PRF reporting requires basic organization information such as tax identification number, fiscal year end date, and federal tax classification. Additionally, PRF recipients may be required to report other assistance received and non-financial information relating to employees (i.e. total, rehires), patients (i.e. visits and admissions) and facility (i.e. staffed beds).
On January 15, 2021, the US Department of Health and Human Services (HHS) opened the reporting portal for providers who received Provider Relief Funds (PRF). The portal is for recipients exceeding $10,000 in PRF payments to complete post-payment reporting requirements. The portal is currently open only for registration, not reporting, because also on January 15, 2021, HHS announced that it was postponing the reporting deadline due to the enactment of the Coronavirus Response and Relief Supplemental Appropriations Act of 2021. This Act added another $3 billion in funding to the PRF program and included language specific to reporting requirements. HHS has been working to update the PRF reporting requirements to be consistent with the new law.
At present, there is no deadline for completing registration on the portal, but providers will be required to complete this first step in order to advance and fulfill their reporting requirements once HHS announces the new deadline to do so. Recipients will later receive notification about when they should complete the second step of submitting reporting requirements information on the use of funds. U.S. Health Resources and Services Administration (HRSA) will send a broadcast email to the email address provided during the registration process. For now, we encourage the recipients exceeding $10,000 in PRF payments to complete the registration process promptly. It takes at least 20 minutes to complete and must be completed in one session. Accordingly, you will want to make sure that you have all of the information required to register before you begin.
Information required to register is as follows:
- Tax ID Number (TIN) (or other number submitted during the application process (e.g., Social Security Number, Employer Identification Number (EIN))
- Business name (as it appears on a W-9) of the reporting entity
- Contact information (name, phone number, email) of the person responsible for submitting the report
- Address (street, city, state, five digit zip code) of the reporting entity as it appears on a W-9
- TIN(s) of subsidiaries (if a provider is reporting on behalf of subsidiary(ies) – in a list delimited by commas, e.g.,123456789,987654321,135791357)
- Payment information (for any of the payments received)
- TIN of entity that received the payment
- Payment amount
- Mode of payment (check or direct deposit ACH)
- Check number or ACH settlement date
- A username (in the form of an email) and a password will be created during the registration process.
HHS will also provide updates on its website when new reporting instructions and next steps for completing reporting requirements become available. Recipients will need to provide specific information to ensure appropriate use of PRF payments.
Recipients that spend a total of $750,000 or more in federal funds (including PRF payments and other federal financial assistance) during a fiscal year are subject to Single Audit requirements, as set forth in the regulations at 45 CFR 75.501. The recipients of Provider Relief Fund payments may be subject to additional auditing to ensure the accuracy of the data submitted to HHS for payment. According to HHS, any recipients identified as having provided inaccurate information to HHS will be subject to payment recoupment and other legal action.
Finally, all recipients of Provider Relief Fund payments are required to maintain appropriate records and cost documentation.
Our office is available to assist you with your PRF reporting questions and with complying with the Single Audit requirements. Please contact us (609) 641-4000 ext. 137 with any questions.
