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Provider Relief Fund – General Reporting Requirements

Through the CARES Act, the federal government allocated $178 billion to be distributed through the Provider Relief Fund (PRF) among eligible Medicare providers with the intent to reimburse some of the COVID-19 related expenses or lost revenue. On April 10, 2020, the first round of payments was distributed. Additional distributions followed later during the year. The amount each provider received was based on the percentage of prior year patient revenue. Each provider had to accept or reject the funds within 90 days of receipt. In order to accept the funds, each provider had to sign an attestation and agree to meet certain terms and conditions.

A very important question was whether these funds were a loan or a grant that needed to be repaid. The answer is these funds do not need to be repaid as long as the terms and conditions are met. The list of terms and conditions covers multiple topics such as eligibility requirements of the providers, eligible vs non-eligible expenses, and necessary disclosures. However, it’s important to point out the terms and conditions also require compliance with reporting requirements as specified by the Secretary of Health and Human Services (HHS). These reporting requirements apply to all past and future PRF payments. As part of this post-payment reporting process, recipients who received one or more payments exceeding $10,000 in the aggregate during a “Payment Receipt Period” (Table 1) are required to report in each applicable “Reporting Time Period” (Table 2).

The PRF recipients must only use payments for eligible expenses during the period of availability, as outlined in Table 1 below. The period of availability of funds is based on the date the payment is received.

Table 1: Deadlines for Use of Funds
 Payment Received PeriodDeadline to Use Funds
Period 1April 10, 2020 to June 30, 2020June 30, 2021
Period 2July 1, 2020 to December 31, 2020December 31, 2021
Period 3January 1, 2021 to June 30, 2021June 30, 2022
Period 4July 1, 2021 to December 31, 2021December 31, 2022

The PRF recipients who received one or more payments exceeding $10,000 in the aggregate during a “Payment Received Period” are required to report in each applicable “Reporting Time Period” as indicated in Table 2 below.

Table 2: Reporting Time Periods
 Payment Received Period
(Payments Exceeding $10,000 in Aggregate Received)
Reporting Time Period
Period 1April 10, 2020 to June 30, 2020July 1, 2021 to September 30, 2021
Period 2July 1, 2020 to December 31, 2020January 1, 2022 to March 31, 2022
Period 3January 1, 2021 to June 30, 2021July 1, 2022 to September 30, 2022
Period 4July 1, 2021 to December 31, 2021January 1, 2023 to March 31, 2023

Reporting must be completed and submitted to HRSA by the last date of the reporting time period. PRF recipients that do not report within the respective reporting time period are out of compliance with payment Terms and Conditions and may be subject to recoupment.

The reporting may be quite complicated, and it may take several weeks to gather all the necessary information.

New Developments.

On September 10th, 2021, the U.S. Department of Health and Human Services (HHS) made two important announcements regarding the Provider Relief Fund (PRF): a new $25.5 billion round of funding and a 60-day grace period following the first reporting deadline on September 30.

The September 30, 2021 Reporting Period 1 deadline has not changed. However, in response to challenges providers are facing given the Covid surges and natural disasters around the country, a 60-day grace period is in place. This period allows providers to come into compliance with their PRF reporting requirements should they have failed to meet the September 30, 2021 deadline to report the use of payments received between April 10 and June 30, 2020. HHS indicated it will not initiate any recoupment or enforcement actions for 60 days following the deadline, allowing for a period of enforcement discretion from October 1 – November 30, 2021. Any unused PRF payments from the first Payment Received Period must now be returned no later than 30 days after the end of the grace period (December 30, 2021). This grace period only pertains to the Reporting Period 1 report submission deadline. There is no change to the Period of Availability for use of PRF payments. Additional information and reporting resources can be found on the PRF Reporting & Auditing page.

It’s important to start acting now. If you have questions or need assistance, we are here to help. You can also find a great deal of information on the HRSA website in the Q&A section: Provider Relief Fund General Information.

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