Alert

New Guidance and Reporting Deadlines for Provider Relief Fund Distributions

June 16, 2021

On June 11, 2021, the Health Resources and Services Administration (“HRSA”) released additional reporting guidance and portal reporting deadlines for healthcare provider recipients of the Provider Relief Fund (PRF) distributions (applicable only if the provider received in excess of $10,000 of PRF). Previously, the reporting portal opened on January 15, 2021, with instructions that the reporting deadlines had been extended and would be communicated at a later date. Further, the January 15 notice encouraged providers to register their organizations in the portal and would be communicated future notices and instructions. The updated instructions as of June 11 provide these guidelines and deadlines for use of funds and portal reporting window based on dates when PRF distributions were received:

Summary of Reporting Requirements

Period Payment Received Period
(Payments Exceeding $10,000 in Aggregate Received)
Deadline to Use Funds Reporting Time Period
Period 1 April 10, 2020 to June 30, 2020 June 30, 2021 July 1, 2021 to September 30, 2021
Period 2 July 1, 2020 to December 31, 2020 December 31, 2021 January 1, 2022 to March 31, 2022
Period 3 January 1, 2021 to June 30, 2021 June 30, 2022 July 1, 2022 to September 30, 2022
Period 4 July 1, 2021 to December 31, 2021 December 31, 2022 January 1, 2023 to March 31, 2023

The update explains that recipients of General Distributions may report at the parent company level regardless of who attested to receive the funds. However, recipients of Targeted Distributions must report at the entity (TIN level) that received these distributions.

The update provides six steps for reporting on use of funds. Detailed guidance for each step is included in the notice.

  1. Interest Earned on PRF Payments
  2. Other Assistance Received
  3. Use of SNF and Nursing Home Infection Control Distribution Payments (if applicable)
  4. Use of General and Other Targeted Distribution Payments
  5. Net Unreimbursed Expenses Attributable to Coronavirus
  6. Lost Revenues Reimbursement

Additional specifications included in the report includes guidance for:

  • The data elements that are to be included with the portal reporting.
  • Reporting whether the entity was subject to Single Audit as well as submitting the Single Audit report.
  • Reporting lost revenue calculations, especially those intending to submit option (c) or iii for using an alternative methodology for determining the Lost Revenue calculation.

Your Cherry Bekaert healthcare team continues to evaluate changes in the requirements and the impacts they make on our clients. Stay tuned for more updates from us, or please contact us regarding questions or information specific to your company or organization.


Related Guidance: