CARES Act Reporting Requirements for Provider Relief Funds

The Department of Health and Human Service (HHS) reporting portal for Provider Relief Funds (PRF) opens on January 15, 2020 with the first “use of funds” deadline set for February 15th. In addition to these important dates and others throughout 2021, PRF recipients should ensure they are familiar with the Coronavirus Aid, Relief, and Economic Security (CARES) Act reporting requirements.

2021 Deadlines

• January 15, 2021 – Department of Health and Human Services (HHS) portal for PRF reporting opens
• February 15, 2021 – PRF report submission due (assuming all proceeds were accounted for in 2020)
• July 31, 2021 – Final deadline for submitted PRF report
• September 30, 2021 – Due date for single audit or program-specific audit reports for Dec. 31 year-end, or the earlier of 60 days from the date of the issuance of the audit report

PRF recipients can begin submitting PRF reports documenting how funds were spent or attributed beginning January 15, 2021. The level of reporting requirements varies by the amount received:

• Entities that received less than $10,000 in total from the PRF do not have to file a report.
• Entities that received more than $10,000 but less than $500,000 must submit a simplified report with only these broad expense categories: general administrative expenses and other healthcare-related expenses.
• Entities that received more than $500,000 in PRF must submit a detailed report described below.
• Entities that received over $750,000 in PRF may also be subject to an audit per federal regulations (45 CFR 75.501, single audit requirements).

Audit Requirements

If you received more than $750,000 in PRF, you may require an audit per federal regulations. Audits are required for entities (nonprofit and commercial as it relates to PRF, per HHS guidelines) that expended over $750,000 from federal grant funds in a reporting period. Note that receiving $750,000 is not the same as expending $750,000 because some funds could have been received in cash but not yet expended.

Let Aprio Help

Aprio is continuously monitoring new guidance from HHS to ensure we have the latest information when advising our clients. If you need assistance meeting the reporting requirements for Provider Relief Funds, please reach out to talk with one of our advisors.