HHS Releases PRF Reporting Guidance

COVID-19; Reimbursement

On September 21, the Department of Health and Human Services (HHS) released new information regarding reporting requirements for recipients of funds from the CARES Act Provider Relief Fund as well as additional information related to potential future audits.   

This update provides guidance for our sector that CARES Act funds can be used to make up for lost revenue up to 2019 net operating income levels. AHCA/NCAL has worked with HHS to advocate for an updated definition of revenue, which is a significant improvement over a preliminary set of reporting guidance shared with stakeholders in August.  

What the HHS Announcement Means 

Reporting Requirements 

In July, HHS provided a preview of reporting requirements for entities that received funds through the Provider Relief Fund. In the preview, HHS indicated that entities receiving over $10,000 would be required to submit reports within 45 days of the end of the calendar year. Also, HHS indicated reporting requirements on August 17. After a delay, HHS released the more detailed reporting requirements​.   

Notable pieces of the reporting requirements: 

  • Purpose of funds – at a high level, reporting entities will need to report on: 1) healthcare-related expenses attributable to coronavirus; and 2) payment amounts attributable to “lost revenue”;
  • Acceptable expenses – the guidance discusses what expenses HHS views as appropriate for purposes of healthcare-related expenses attributable to coronavirus;
  • “Lost Revenue” defined – the guidance offers insight into how HHS views “lost revenues”; 
  • Accounting other funds – as part of the “lost revenue” definition, HHS will be asking applicants for an accounting of other assistance the provider received, including loans from Treasury and the Small Business Administration, CARES Act testing funds, and other sources of public and private revenue; and 
​HHS notes the September 21 guidance does not apply to Nursing Home Infection Control distribution nor Rural Health Clinic Testing distribution or claims from the HRSA fund for the uninsured. Reporting requirements for these distributions will be released at a later date.   

Additional HHS Information  

HHS has also released a new webpage with additional information about reporting and audits. Through the new webpage, HHS has indicated they will be posting the reporting template, case examples, and the reporting system portal which will be available in “early 2021.” HHS had previously indicated the reporting system would open in October 2020.  

What It Means for the Membership 

The membership should consider both Reporting and Single Audit:  

Reporting:  Anyone who has received funds from the Provider Relief Fund should review these new reporting requirements and ensure they are prepared to comply early next year based upon the September 21 release as well as additional information AHCA/NCAL will share as soon as HHS provides additional detail; and 

Single Audit:  The American Institute for Certified Public Accountants (AICPA) has made available a free webinar on Single Audit. Of note, the AICPA Governmental Audit Quality Center webinar is targeted to the usual entities subject to Single Audit, Not-for-Profit entities. The “Preparing for First Single Audit for Auditees” event is located here. Registration is required and there is no fee. Once registered, AHCA/NCAL members will immediately have access to the webinar as well as AICPA’s COVID-19 information. There is no CPE for listening to an archive. Later in October after HHS releases the PRF Single Audit guidance, AICPA will make a second free webinar available tailored to For-Profit entities.   ​