HHS Issues Initial Reporting Requirements for Provider Relief Fund
Without announcement or notice, the U.S. Department of Health and Human Services (HHS) notified Monday, July 20, 2020, that providers who have received a total of $10,000 or more in Provider Relief Fund (PRF) payments now have a looming reporting deadline of February 15, 2021. Detailed reporting instructions will be issued by August 17, 2020.
If you received a payment from the General Distribution (including the $30 billion tranche, the $20 billion tranche, or Medicaid, Dental & CHIP allocation) or a Targeted Distribution this applies to you.
Remember, HHS previously announced that PRF recipients were not required to submit quarterly reports to HHS or the Pandemic Response Accountability Committee. HHS has revised that guidance. Here are the key dates:
- August 17, 2020 – Detailed reporting instructions will be released
- October 1, 2020 – Reporting system will become available
- February 15, 2021 – By this date, recipients must report on their expenditures through December 31, 2020
- July 31, 2021 – By this date, recipients with unexpended funds following December 31, 2020, must submit a second and final report on their expenditures
There is one ambiguity worth mentioning here. Since HHS’ notice provides that recipients with unexpended funds following December 31, 2020, must submit a “second and final report” by July 31, 2021, there is speculation that July 31, 2021, may be the final deadline for all PRF distributions to be used or returned to HHS. We expect future guidance from HHS to clarify this issue.
HHS also explained that its Health Resources and Services Administration will offer Q&A sessions via webinars in advance of the submission deadlines—additional details regarding these sessions will follow.
Our Chambliss team continues to monitor health care developments and other legal impacts of the COVID-19 pandemic. Please contact Jed Roebuck, Courtney Keehan or your relationship attorney if you have questions or need additional information.
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The material in this publication was created as of the date set forth above and is based on laws, court decisions, administrative rulings, and congressional materials that existed at that time, and should not be construed as legal advice or legal opinions on specific facts. In some cases, the underlying legal information is changing quickly in light of the COVID-19 pandemic. The information in this publication is not intended to create, and the transmission and receipt of it does not constitute, a lawyer-client relationship. Please contact your legal counsel for advice regarding specific situations.