HHS Relief Funding Reporting FAQs – by Syed Nishat

Frequently Asked Questions about Provider Relief Fund Reporting – By Syed Nishat

During the COVID-19 pandemic, many healthcare facilities were able to utilize the Provider Relief Fund to provide a financial cushion during the challenging time. For those who received at least $10,000 during the first half of 2020, the reporting requirement deadline is 9/30/2021, with other upcoming reporting deadlines for funds received later. To make it easier to submit reports correctly, the Department of Health and Human Services (HHS) has provided some guidance, worksheets, and several FAQs to help in the report preparation in advance of submitting these reports through the portal. We’ve collected some of the most frequently asked questions here.

1. Where can I access the reporting portal?

The reporting portal is available on the HHS website. Click here for access. To gain access, providers must register for the portal before any reports can be submitted. To register, simply click on the Register button on the reporting website link provided above. The portal utilizes two-step authentication for users. After receiving login credentials, you will be required to enter a separate 6-digit code for each login. This code will be sent to the user’s email address. The portal is only open during the reporting periods.

2. What are the spending deadlines for funds received through the Provider Relief Fund?

• Funds received 4/10 to 6/30/2020 must be used by 6/30/2021
• Funds received 7/1 to 12/31/2020 must be used by 12/31/2021
• Funds received 1/1 to 6/30/2021 must be used by 6/30/2022
• Funds received 7/1 to 12/31/2021 must be used by 12/31/2022

3. What are the reporting deadlines for funds received through the Provider Relief Fund?

• Funds received 4/10 to 6/30/2020: reporting period 7/1 to 9/31/2021
• Funds received 7/1 to 12/31/2020: reporting period 1/1 to 3/1/2022
• Funds received 1/1 to 6/30/2021: reporting period 7/1 to 9/30/2022
• Funds received 7/1 to 12/31/2021: reporting period 1/1 to 3/31/2023

4. Are there any extensions for these deadlines?

Information from HHS has indicated that the spending and reporting deadlines provided are hard dates and that no extensions will be granted. However, due to complications from recent COVID surges and natural disasters, HHS has announced a 60-day grace period for those in reporting Period 1. The 9/30/2021 deadline has not changed, however, the grace period will allow providers to come into compliance even if they miss the deadline. The grace period begins 10/1/2021 and will end 11/30/2021. After that time, providers who are still not in compliance will be subject to enforcement actions. This grace period only applies to providers with a reporting deadline of 9/30/2021. Later deadlines are unaffected by this announcement. This also does not affect any spending deadlines.

5. Do other assistance programs, such as PPP loans, need to be reported at the same time?

Any other loans or reimbursements received for COVID-related programs must also be reported. As Provider Relief Fund monies can be used for eligible expenses that are not reimbursed by another source, those are the only expenses that can be reported under the Provider Relief Fund. For the purposes of these report deadlines, HHS requires providers to report all expenses, then to report those expenses and lost revenue amounts remaining after payment assistance from other programs separately. The system’s calculator does not do this automatically, as providers will find this applied differently, so it is critical to follow HHS guidance. HHS has made this data worksheet available for use, as well as this FAQ that breaks down requirements for different providers.

6. In addition to expenses, should lost revenue be reported?

If eligible expenses reported by the provider are equal to the amount received from the Provider Relief Fund, then no details pertaining to lost revenue must be provided. While this was initially part of HHS’s reporting requirement, new guidance does not include this unless the funds received in Period 1 of the program (4/10/2020-6/30/2020) were used completely for eligible expenses. In this case, detailed patient care revenue for 2019, 2020, and 2021 must be provided in reporting.

7. How will lost revenue calculations be determined?

While early information from HHS indicated this should be calculated annually, this method would have removed eligibility for some providers, as lost revenue from the earlier portions of 2020 was offset later in the year. Under current HHS guidance, calculations should be done on a quarterly, standalone basis. Quarters with increased revenue should be reported as a zero amount or should not be counted in the calculation at all.

8. How should “surplus” expenses and lost revenues be reported?

Should a provider have eligible expenses relating to the COVID-19 pandemic that are greater than the amount of Provider Relief Fund received within the first period, the “surplus” amount may be carried forward to a future reporting period. This applies to lost revenue as well. However, shortfalls cannot be carried forward to future period.

9. How should shortfalls be handled under the spending deadlines?

In the case of a provider ending a spending period with leftover money from the Provider Relief Fund, this amount may not be rolled over to a future reporting period. HHS has indicated that any amount received during Period 1 (4/10/2020 to 6/30/2020) that was not spent on eligible expenses or to support lost revenue during that time must be returned to the government within 30 days of the first reporting period, by 10/30/2021. For subsequent reporting periods, the repayment of shortfalls will have a similar 30-day deadline.

10. How can shortfall amounts be returned?

The process to return funds has two parts. Initially, there is an online form to complete in the Return Funds PRF Funds Portal. Once that is completed, you will be redirected to the second section, which will allow you to transfer funds via Pay.gov. More information regarding this process is available within the portal itself.

As the reporting process continues, there will likely be additional guidance from HHS on calculations, reporting features, and repayment. For complete information, please make sure to visit the HHS Provider Relief Fund website at https://www.hrsa.gov/provider-relief/reporting-auditing.