HHS Releases Reporting Requirements for Provider Relief Fund Recipients

On September 18, the Department of Health and Human Service (HHS) released post-payment reporting requirements for the Provider Relief Funds (PRF). Any recipients who received PRF of $10,000 or more will be required to demonstrate how they used PRF for allowable expenses and losses. In this article, Aprio will provide details to help you understand your obligations and the resources available to you, including:

• Reporting is set to begin in early 2021 (previously October 1, 2020)
• Two Expense categories for providers receiving between $10,000 and $499,999
• Sub-categories for providers receiving $500,000+
• Single audit requirements for providers receiving $750,000+

New Guidance on Classifying Expenses and Measuring Lost Revenues

The September 18 notice provides additional clarification regarding the types of expenses the HHS defines as attributable to COVID-19, as well as the process for measuring lost revenues.

For providers who received between $10,000 and $499,999 in PRF payments, any expenses incurred in 2020 will be classified into two categories: general and administrative expenses or healthcare-related expenses.  Providers who received PRF of $500,000 or more must classify expenses into sub-categories, which are outlined further in the new notice.

All providers applying PRF to lost revenues must utilize the calculation proposed by the HHS, which is a year-over-year comparison of net operating income from patient care. The HHS requires a calendar year comparison of 2019 to 2020, with a break-down of revenues by quarter. Providers will be required to report quarterly general and administrative expenses, as well as healthcare-related expenses, for purposes of calculating net operating income from patient care.

Expectations on Reporting, Disbursement, and Audits

While prior communications from HHS indicated the reporting would begin on October 1, 2020, the latest guidance clarified that reporting will begin in early 2021.

Any PRF not disbursed by December 31, 2020 must be used by June 30, 2021.  PRF expended in 2021 will be considered attributable to lost revenue, not additional expenses resulting from COVID-19, and net patient care income will be measured in comparison to the first six months of calendar year 2019.

Additionally, some providers should anticipate and prepare for an audit triggered by PRF disbursement. Providers who have received $750,000 or more in aggregate from Federal awards, including PRF, will be subject to audit requirements.  Read more on these audit requirements in our article.

Let Aprio Help

Aprio’s advisors are ready and available to consult on your reporting and audit requirements. Our team offers specialized and personalized expertise, creating a smoother, stress-free audit experience that allows you to keep your eye on the ball.

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.