Recipients of Provider Relief Funds
Catch a Break in Reporting

The U.S. Department of Health & Human Services (HHS) has added more FAQs subsequent to our last communication regarding the Provider Relief Fund (PRF). The complete list of FAQs can be found here . HHS has issued the following FAQs on reporting time frames that providers should be aware of.

The Terms and Conditions f or all Provider Relief Fund payments require recipients who receive at least $150,000 in the aggregate from any statute primarily making appropriations for the coronavirus response to submit quarterly reports to HHS and the Pandemic Response Accountability Committee. This requirement is from section 15011 of the CARES Act. What do providers need to do in order to be in compliance with this provision in the Terms and Conditions?  
 
Recipients of Provider Relief Fund payments  do not need to submit a separate quarterly report  to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision. For all providers who attest to receiving a Provider Relief Fund payment and agree to the Terms and Conditions (or retain such a payment for more than 90 days), HHS is posting the names of payment recipients and their payment amounts on its public website. HHS Is also working with the Department of Treasury to reflect the aggregate total of each recipient’s attested to Provider Relief Fund payments on USAspending.gov. Posting these data meets the reporting requirements of the CARES Act. See Appendix A of OMB Memo M-20-21 [Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)].
 
However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient’s use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.

How long are the Terms and Conditions of the Provider Relief Fund applicable?

All recipients receiving payments under the Provider Relief Fund will be required to comply with the Terms and Conditions. Some Terms and Conditions relate to the provider’s use of the funds, and thus they apply until the provider has exhausted these funds. Other Terms and Conditions apply to a longer time period, for example, regarding maintaining all records pertaining to expenditures under the Provider Relief Fund payment for  three years  from the date of the final expenditure.

A Special Note to Pennsylvania skilled nursing facilities  who received a remittance advice from Pennsylvania Medicaid on June 22, 2020, that has their distribution, to be paid on July 1, 2020, from the Pennsylvania Senior Protection Act from the CARES Act. These funds can be used for COVID-19 expenses that the facility has incurred from March 1, 2020, through November 30, 2020.
ACT is presenting free educational webinars that may assist in building your knowledge base regarding the handling of funding: Tax & Accounting Impact of COVID-19 and PPP Loan Forgiveness What You Need to Know . Register by clicking one of the links. For more information contact your ACT representative or email us at  info@actcpas.com .