HHS Releases Provider Relief Fund Reporting Guidance

On September 21, 2020, the U.S. Department of Health and Human Services (HHS) released new information regarding the reporting requirements for recipients of funds from the CARES Act Provider Relief Fund that exceeded $10,000.  The entirety of the updated reporting requirements can be found here, and notably, under the updated reporting requirements, the CARES Act funds can be used to make up for lost revenue up to 2019 net operating income levels.  Please note, these updated reporting requirements do not apply to the Nursing Home Infection Control Distribution, the Rural Health Clinic Testing Distribution, or to reimbursement from the Health Resources and Services Administration (HRSA) Uninsured Program.  Separate reporting requirements will be announced for those distributions.

Other notable pieces of the updated reporting requirements include:

• ​Purpose of Funds:  At a high level, entities will need to report on healthcare-related expenses attributable to COVID-19 and 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 COVID-19 (i.e., supplies, equipment, IT);
• Lost Revenue:  The guidance provides insight into how HHS views “lost revenues.”  Revenues and expenses will include all lost patient care revenues and patient care cost/expense impacts.
• 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 the Small Business Administration, CARES Act testing funds, and other sources of public and private revenue.
• Single Audit Requirements:  Entities that expended over $750,000 of federal funds (including the Provider Relief Fund) will be subject to Single Audit Requirements.

HHS had previously indicated the reporting system would be available October 2020, but HHS has now indicated the following key dates:

• January 15, 2021: Reporting system opens for providers.
• February 15, 2021:  First reporting deadline for all providers on use of funds.
• July 31, 2021:  Final reporting deadline for providers who did not fully expend funds prior to December 31, 2020.

Free Webinar on Single Audit by the American Institute for Certified Public Accountant (AICPA)

Looking ahead to future audits, AICPA has made available a free webinar on Single Audit. Registration is required, and there is no fee.  Once registered, you will immediately have access to the webinar, as well as AICPA’s COVID-19 information.  However, it should be noted that the AICPA webinar is targeted to the usual entities subject to Single Audit — not-for-profit entities.  After HHS releases the Provider Relief Fund Single Audit guidance, which is expected in late October, AICPA will release a second, free webinar tailored to for-profit entities.   ​

ACCESS HERE

IHCA/INCAL will keep you updated as additional details are known, including when HHS’s reporting template, educational webinars, and case examples are released.  AHCA/NCAL will also continue to work with the major CPA associations and other health care provider groups to secure additional details and shape the reporting and auditing process.