On June 11, 2021, HHS updated the reporting requirements for recipients of Provider Relief Fund payments. The new notice supersedes the Post Payment Reporting Requirements Notice released on January 15, 2021.
The changes per the June 11, 2021 notice include:
- The period for using the funds on (1) qualified expenses related to preventing, preparing for, and responding to coronavirus and (2) lost revenues related to coronavirus will be based on the date the payment is received instead of requiring the payments to be used by June 30, 2021, regardless of when they were received. This provides extra time to accumulate qualified expenses and lost revenue for reporting purposes. We are currently waiting for additional information from HHS regarding the interaction of lost revenue and the extended reporting period. The new deadlines are as follows:
- Recipients must report for each Payment Received Period where they received one or more payments exceeding a total of $10,000. Originally the reporting requirement was $10,000 on a cumulative basis for all payments received. To be allowable, an expense must be used to prevent, prepare for, and respond to coronavirus. The PRF payment can also be used to replace lost revenue due to coronavirus. Expenses incurred prior to receiving PRF payments can also be considered eligible if they were used to prevent, prepare for, and respond to coronavirus. However, HHS would regard it as unusual for expenses prior to January 1, 2020, to be eligible.
- The deadline for reporting the use of funds has been extended from 30 days to 90 days as follows:
- The Provider Relief Reporting Portal will be open on July 1, 2021. Providers should register for the PRF Reporting Portal prior to the required Reporting Time Period Dates (prfreporting.hrsa.gov/s/). HHS has indicated the registration process takes about 20 minutes and must be completed in one session. For the registration form to be saved, it must be completed. To complete the registration, providers will need:
- Tax ID number (Social Security Number or Employer ID Number) that was used to apply for the funds.
- Business name and address of the entity being reported (as it appears on Form W-9).
- Name, phone number, and email of the person responsible for submitting the report.
- Information for each payment received including TIN, Payment Amount, Method of Payment (Check or Direct Deposit ACH), and the check number or date of ACH Settlement.
*** The reporting entity will have to create a username (an e-mail address) and a password during the registration process ***
Actions you should start taking now:
- Gather all expenses incurred to prepare for, prevent, and respond to coronavirus in the time period related to the payment(s) you received. This should include all:
- PPE – gloves, gowns, masks, etc.
- Disposable/single use patient care items.
- Hand sanitizer, patient screening materials, cleaning supplies, safety materials, and masks for patients.
- Any staff training costs for the prevention of coronavirus.
- Any expenses related to ventilation and cleaning for the prevention of coronavirus.
- Gather all revenue data by quarter for each of the following payor types from January 2019 – through the applicable quarter end related to the time period specified for the payment(s) you received:
- Medicare Part A or B
- Medicare Part C
- Medicaid/Children’s Health Insurance Program (CHIP)
- Commercial Insurance
- Self-Pay (No Insurance)
Lance Jacob, EA – As a partner of Naden/Lean, LLC, Lance provides start-up services to new businesses including working with banks to help obtain financing. Lance works closely with our Dental CPA clients to ensure they are in compliance with the federal, state, and local taxing authorities with respect to employment, business tax, and reporting issues.