HHS Updates the PRF Reporting Requirements
On October 22, the U.S. Department of Health and Human Services (HHS) announced expanded eligibility for the Phase 3 General Distribution of the CARES Act Provider Relief Fund (PRF), along with revisions to the reporting requirements. With respect to the reporting requirements, as detailed in a separate memo, HHS described the rationale for the reporting requirement changes, noting that the “decision to prohibit most providers from using PRF payments to become more profitable than they were pre-pandemic, in order to conserve resources to allocate to providers who were less profitable, has generated significant attention and opposition from many stakeholders and Members of Congress. There is consensus among stakeholders and Members of Congress who have reached out to HHS that the PRF should allow a provider to apply PRF payments against all lost revenues without limitation. In consideration of this feedback, HHS has amended its reporting instructions to provide for the full applicability PRF distributions to lost revenues.” The revised reporting requirements state that “[r]ecipients may apply PRF payments toward lost revenue, up to the amount of the difference between their 2019 and 2020 actual patient care revenue.” This differs from the initial reporting requirements which focused on net profit but still retains the focus on comparing year over year.
As detailed within the application instructions, all providers receiving more than $10,000 are subject to key reporting requirements, with the first deadline for reporting February 15, 2021. For the updated reporting elements, visit here, along with a summary of those requirements here. In addition, as noted within the reporting requirements document, all providers that expend more than $750,000 in Federal funds (including PRF and the Paycheck Protection Program funds) will be subject to additional audit requirements. For additional information, visit the Reporting Requirements and Auditing page and read the Auditing and Reporting Requirements FAQs. More information related to this program can be found on the Provider Relief Fund website.