HHS provides update for Provider Relief Fund reporting requirements

The Provider Relief Fund was established as part of the CARES Act to reimburse eligible health care providers for expenses or lost revenues attributable to COVID-19. Recipients were required to attest to the Department of Health and Human Services’ (HHS) terms and conditions, which in part requires recipients to submit a report within ten days after the end of each calendar quarter detailing how the funds were used.

Initially, HHS indicated the reporting requirement would begin for the calendar quarter ending June 30, 2020, meaning the first reporting deadline was July 10, 2020. However, HHS later retracted that statement and stated recipients do not need to submit a quarterly report on July 10, 2020.

In addition, HHS planned to release detailed instructions and a data collection template for these quarterly reports on August 17, 2020. However, on August 14, 2020 HHS announced that this information would “soon be made available.”

While recipients await the detailed instructions and data template, here is what we do know now about the reporting deadlines:

• For expenditures through December 31, 2020, all recipients must submit a report to HHS within 45 days of the end of 2020.
   
• Recipients who expended funds in full prior to December 31, 2020 may submit a single, final report to HHS any time between October 1, 2020 and February 15, 2021.
   
• Recipients with funds unexpended after December 31, 2020 must submit a second and final report to HHS no later than July 31, 2021.

These reports will allow providers to demonstrate compliance with the terms and conditions, including use of funds for allowable purposes.

If you have any questions about this topic, please reach out to the authors of this blog.

Nicole Jobe is a member of Thompson Coburn’s Health Care group.