Health and Human Services Provider Relief Fund – Big Reveal on Reporting Requirements

Health and Human Services (HHS) just published long-awaited guidance regarding the reporting requirements related to General and Targeted Distribution of Provider Relief Funds.

This guidance does not apply to the Nursing Home Infection Control distribution or the Rural Health Clinic Testing distribution.

The CARES Act required that providers meet certain terms and conditions if a provider retains a Provider Relief Fund payment. Those providers were required to attest that they meet specific Terms and Conditions of the payment (https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#terms-and-conditions).

One of the terms was ambiguously stated as follows: “The Recipient shall submit reports as the Secretary determines are needed to ensure compliance with conditions that are imposed on this Payment, and such reports shall be in such form, with such content, as specified by the Secretary in future program instructions directed to all Recipients.”

The previous notice released on July 20, 2020, and subsequently updated on August 14, 2020, specified that the reporting system will be available for recipients of the funds on October 1, 2020. All recipients must report within 45 days of the end of the calendar year 2020 on their expenditures through the period ending December 31, 2020. However, no specific information related to the details of the reporting was provided at that time.

The Post-Payment Provider Relief Fund reporting requirement guidance can be downloaded here.

Reference

Post payment notice of reporting requirements. (2020). Retrieved September 24, 2020, from https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html#terms-and-conditions

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Lyuda Eisenman
Lyuda Eisenman

Lyuda Eisenman is a Tax Shareholder for BeachFleischman PC. She has provided accounting, tax and numerous consulting services for a variety of privately held companies and has over 12 years of experience in public accounting.