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On July 20, 2020, the Department of Health & Human Services (HHS) posted a notice for post-payment reporting requirements for the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (P.L. 116-136) and Paycheck Protection Program and Health Care Enhancement Act (P.L. 116-139) Provider Relief Fund (PRF) general and targeted distributions.

The HHS notice informed recipients who received one or more payments exceeding $10,000 in the aggregate from the PRF of the timing and future reporting requirements. HHS will issue detailed instructions regarding these reports by August 17, 2020, and the reporting system will be available for reporting on October 1, 2020.

The Health Resources & Services Administration (HRSA) is administering the distribution of payments under the PRF program funded through appropriations from these acts:

  • CARES Act (P.L. 116-136)
  • Paycheck Protection Program and Health Care Enhancement Act (P.L. 116-139)

Each provider that received a payment from the PRF and used any part of the payment agreed to a set of terms and conditions that, among other obligations, requires each recipient to submit reports to HHS in its requested format.

The reporting instructions will provide directions on reporting obligations applicable to any provider that received a payment from these CARES Act/PRF distributions:

General Distributions:

  • Initial Medicare Distribution
  • Additional Medicare Distribution
  • Medicaid, Dental, & CHIP Distribution

Targeted Distributions:

  • High-Impact Area Distribution
  • Rural Distribution
  • Skilled Nursing Facilities Distribution
  • Indian Health Services Distribution
  • Safety Net Hospital Distribution

The intent of the reports is to allow providers to demonstrate compliance with the terms and conditions related to the allowable use of each PRF payment received. HRSA is planning on providing recipients with question-and-answer sessions via webinar in advance of the submission deadline.

Notice on Timing of Reports

The reporting system will become available to recipients for reporting on October 1, 2020.

  • All recipients must report within 45 days of the end of calendar-year 2020 on their expenditures through the period ending December 31, 2020.
  • Recipients who have expended funds in full prior to December 31, 2020, may submit a single final report at any time during the window that begins October 1, 2020, but no later than February 15, 2021.
  • Recipients with funds unexpended after December 31, 2020, must submit a second and final report no later than July 31, 2021.
  • Detailed PRF reporting instructions and a data collection template with the necessary data elements will be available on the HRSA website by August 17, 2020.

We’ll continue to monitor activity related to this notice from HHS. If you have any questions, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below.

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