HRSA Updates Reporting Requirements for Provider Relief Funds

On June 11, 2021, the Health Resources and Services Administration (HRSA) issued a Post-Payment Notice of Reporting Requirements (the Notice) relating to General and Targeted Distributions made under the Provider Relief Fund (PRF).  The Notice supersedes the reporting requirements released on January 15, 2021 and is applicable to past and future PRF General and Targeted Distributions.  The Notice is applicable to the Skilled Nursing Facilities and Nursing Home Injection Control distributions.  However, the Notice does not apply to the Rural Health Clinic COVID-19 Testing Program or claims reimbursements from the HRSA COVID-19 Coverage Assistance Fund.

The Notice extends the deadline that providers have to use certain PRF funds depending upon when the funds were received.  There are also new reporting time periods.  The following table details the updated period of availability of funds and the reporting requirements:

Recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report in each applicable Reporting Time Period as indicated above.  Reporting must be completed and submitted to HRSA by the last day of the Reporting Time Period.  PRF recipients that do not report within the respective Reporting Time Period will be out of compliance with payment terms and conditions and may be subject to recoupment.

Steps for Reporting on Use of Funds

Reporting entities will report on their use of funds using their normal basis of accounting (e.g. accrual basis, cash basis).  Recipients will report the following data:

1. Interest earned on PRF Payment(s) – if the PRF payments were held in interest bearing accounts.
2. Other Assistance Received – will report on other assistance received by quarter during the period of availability. Other assistance received includes coronavirus-related relief from Department of Treasury and/or Small Business Administration (SBA); Federal Emergency Management Agency (FEMA); Local, State and Tribal Government Assistance.  Other Assistance includes the Payroll Protection Program.
3. Use of Skilled Nursing Facility and Nursing Home Infection Control Distribution Payments (if applicable) – will report on infection control expenses paid for with these funds. Expenses must be those that another source has not reimbursed and is not obligated to reimburse.
4. Use of General and Other Targeted Distribution Payments – will report on expenses paid for with PRF payments (excluding number 3 above). Expenses must be those that another source has not reimbursed and is not obligated to reimburse.  Expense categories will include General and Administrative and/or other Health Care-Related Expenses by calendar year quarter.  Unreimbursed expenses attributable to coronavirus are considered first in the overall use of funds calculation.
5. Net Unreimbursed Expenses Attributable to Coronavirus – will report on unreimbursed expenses attributable to coronavirus (net after other assistance received and PRF payments are applied) by quarter for the period of availability, broken out as General and Administrative and/or other Health Care-Related expenses.
6. Lost Revenues Reimbursement – PRF payment amounts not fully expended on health-care related expenses attributable to coronavirus may then be applied to patient care lost revenues, if applicable. Recipients may choose to apply PRF payments toward lost revenues using one of three options, up to the amount:
   1. Option i: of the difference between actual patient care revenues
   2. Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues
   3. Option iii: calculated by any reasonable method of estimating revenues

See the Notice for additional details on the Data Elements to be included in the report submission.

Single Audit Requirements

Recipients that expend a total of $750,000 or more in federal funds (including PRF payments and other federal financial assistance) during their fiscal year are subject to Single Audit requirements.  Commercial organizations have two options:  1) a financial related audit of the award or awards completed in accordance with Generally Accepted Government Auditing Standards; or 2) an audit in conformance with the requirements of the Single Audit Act.  We expect there to be further clarifications to the Single Audit requirements as a result of the Notice and we will communicate them as they become known to us.

What does AAFCPAs Advise?

The Notice gives providers more flexibility on the period of time they have to use PRFs, depending upon when the funds were received.  You should summarize the PRFs received based upon the time periods detailed in the table above.  Any funds received prior to June 30, 2020 must be utilized by June 30, 2021 or they will need to be returned to HRSA.   You should revisit how these funds have been used to date in relation to the updated requirements to ensure you can maximize them.

PRFs received after June 30, 2020 should also be summarized to ensure you have a plan to utilize these funds before the applicable deadline to use them.

You should also ensure you have a plan in place to complete the report submission before the reporting deadline.  AAFCPAs is available to advise on these matters.

If you have any questions please contact: Matt Hutt, CPA, CGMA at 774.512.4043, mhutt@nullaafcpa.com; or your AAFCPAs Partner.