HHS Update on Reporting Requirements for Recipients of CARES Act Provider Relief Funds

The Department of Health and Human Services (HHS) this week shared the first specific information on reporting requirements for recipients of provider relief funds authorized under the Coronavirus Aid, Relief, and Economic Security (CARES) Act and Paycheck Protection Program and Health Care Enhancement Act. For more information, click here.

HHS has been clear that recipients receiving one or more payments exceeding $10,000 in the aggregate from the Provider Relief Fund will be required to submit reports to HHS on how the funds have been expended; however, prior HHS guidance has only indicated that the required reports will be required to be “in such form, with such content, as specified by the Secretary in future program instructions.” See here. In this week’s update, HHS announced that detailed instructions, along with a data collection template with the necessary data elements, will be published on the Health Resources and Services Administration (HRSA) website by August 17, 2020. These reporting instructions will be applicable to any provider that received a payment from the following 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 Service Distribution
• Safety Net Hospital Distribution

The HHS update also included an announcement that HRSA, which is in charge of administering the distribution of the payments, will provide recipients with Question and Answer (Q&A) Sessions via Webinar in advance of the submission deadline. The reporting system will become available to recipients for reporting on October 1, 2020.

Additional details on the timing of the required reports are as follow:

• All recipients must report within 45 days of the end of calendar year 2020 (or no later than Feb. 15, 2021) on their expenditures through the period ending Dec. 31, 2020;
• Recipients who have expended funds in full prior to Dec. 31, 2020 may submit a single final report at any time during the window that begins Oct. 1, 2020, but no later than Feb. 15, 2021; and
• Recipients with funds unexpended after Dec. 31, 2020, must submit a second and final report no later than July 31, 2021.

If you have more questions about this alert, please contact Susan Atkinson at 404-815-3635.

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