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Provider Relief Fund Reporting Update

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On June 11, 2021, the U.S. Department of Health and Human Services (HHS) released a revision to the reporting requirements for practices that received Provider Relief Fund (PRF) payments. This revision supersedes the previous update from January of this year. The deadlines for spending the PRF money and for reporting the spending have been extended to relieve some of the burden experienced by smaller practices. The PRF Reporting Portal will be open on July 1, 2021 for providers to begin submitting information. Providers can register for PRF Reporting Portal accounts now.

The revisions apply to those providers who received one or more payments of over $10,000 during a single Payment Received Period (including General, Targeted, Skilled Nursing Facility, and Nursing Home Infection Control distributions). These reporting requirements do not apply to Rural Health Clinic COVID-19 Testing Program, HRSA COVID-19 Uninsured Program or the HRSA COVID-19 Coverage Assistance Fund. Rather than require all payments be used by June 30, 2021, the availability of the funds is dependent on the date the payment was received. The funds received must only be used for expenses within the period of availability. Practices that received one or more payments over, in total, $10,000 must report for each applicable Payment Received Period (rather than $10,000 total across all PRF payment periods). The previous 30-day reporting period has been extended to 90 days. Practices must complete the reporting by the last day of the reporting period or be subject to recoupment. The table below outlines specific dates for both spending and reporting in each period.

 

Payment Received Period

Deadline to Use Funds

Reporting Time Period

Period 1

April 10, 2020 – June 30, 2020

June 30, 2021

July 1 – September 30, 2021

Period 2

July 1, 2020 – December 31, 2020

December 31, 2021

January 1 – March 31, 2022

Period 3

January 1, 2021 – June 30, 2021

June 30, 2022

July 1 – September 30, 2022

Period 4

July 1, 2021 – December 31, 2021

December 31, 2022

January 1 – March 31, 2023

According to the HHS notice, the Reporting Entity is that which registers its Tax Identification Number (TIN) and reports on the payments received by that TIN and/or its subsidiaries. The following table outlines types of PRF recipients.

Type of PRF Recipient

Definition

General Distribution recipient that received payment in Phase 1 only

Entity that received Phase 1 General Distribution payment totaling more than $10,000 in a Payment Received Period

General Distribution recipient with no parent organization or subsidiaries except PRF recipients that received Phase 1 General Distribution only

Entity (TIN level) that received one or more General Distribution payments totaling more than $10,000 in a Payment Received Period

General Distribution recipient with one or more subsidiaries that received payments in Phase 1 to 3

Entity that meets these 3 criteria:

1. Is the parent of one or more subsidiary billing TINs that received General Distribution payments in Phase 1 to 3

2. Has associated providers that were providing diagnoses, testing, or treatment for individuals with possible or actual cases of COVID-19 on or after January 31, 2020

3. Can otherwise attest to the Terms and Conditions

Targeted Distribution recipient (including Nursing Home Infection Control Distribution)

Entity (TIN level) that received Targeted Distribution payments totaling more than $10,000 in a Payment Received Period

Parent entities can report on their subsidiaries’ General Distribution payments whether the subsidiaries received the payments directly or the money was transferred to them by the parent company. The parent entity can report on the General Distribution payments no matter which entity, the parent or subsidiary, agreed to the Terms and Conditions. However, for Targeted Distribution payments, the original recipient is always the Reporting Entity. Parent entities may not report on their subsidiaries’ Targeted Distribution payments regardless of whether the original recipient transferred the payment. A subsidiary Reporting Entity must note the amount of the Targeted Distributions received that were transferred to or by the parent entity. Transferred Targeted Distribution payments are more likely to be audited by HRSA.

For more information regarding the steps for reporting on the use of the PRF payments, see pages 4 through 11 of the HHS publication, “Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements,” linked here.

Works Cited

“HHS Issues Revised Notice of Reporting Requirements and Reporting Timeline for Recipients of Provider Relief Fund Payments.” HHS.gov, U.S. Department of Health & Human Services, 11 June 2021, www.hhs.gov/about/news/2021/06/11/hhs-issues-revised-reporting-requirements-timeline-for-provider-relief-fund-recipients.html?mkt_tok=MTQ0LUFNSi02MzkAAAF9uNPWCB3NbbYhyumTBHK6pfIynjAWdjpGChnfxH4n8K9-TuAevbeYoIoEuSWc6lGpI24iL_kXpC2LNO1TGbDnziySn24OslezAzeFPUdj.

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