This week’s Provider Relief Fund updates include:
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Provider Relief Fund First Reporting Deadline February 15, 2021
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New $5 billion for Nursing Facilities that Participate in COVID-19 Training
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Provider Relief Fund Payments Subject to Single Audit Requirements
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Medicaid Targeted Distribution Updates Deadline Extended
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Provider Relief Fund First Reporting Deadline February 15, 2021
The Department of Health and Human Services (HHS) issued long-awaited reporting requirements for Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000, in the aggregate from the General or Targeted Distributions. A summary follows:
- All PRF recipients must report the calendar year 2020 expenditures on the report due February 15, 2021.
- Detailed instructions regarding these reports, previously scheduled to be released by August 17, 2020, will be issued at a later date.
- The reporting system will become available to recipients for reporting on October 1, 2020.
- Reports can be submitted anytime after the reporting window opens on October 1, 2020.
- Recipients who have expended funds in full prior to December 31, 2020, will only need to submit a single report.
- Recipients with funds unexpended after December 31, 2020, must submit a second and final report no later than July 31, 2021.
- The reports will allow providers to demonstrate compliance with the Terms and Conditions (T&Cs), including the use of funds for allowable purposes, for each PRF payment.
- Health Resources and Services Administration (HRSA) plans to provide recipients with Question and Answer (Q&A) Sessions via Webinar, in advance of the submission deadline.
- These reporting instructions will provide directions on reporting obligations 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
New $5 billion for Nursing Facilities that participate in COVID-19 training
HHS announced new funding of $5 billion of the PRF authorized by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to Medicare-certified long term care facilities and state veterans’ homes (“nursing homes”), to build nursing home skills and enhance nursing homes’ response to COVID-19, including enhanced infection control. This funding could be used to address critical needs in nursing homes including hiring additional staff, implementing infection control “mentorship” programs with subject matter experts, increasing testing, and providing additional services, such as technology so residents can connect with their families if they are not able to visit. Nursing homes must participate in the Nursing Home COVID-19 Training to be qualified to receive this funding. This new funding is in addition to the $4.9 billion previously announced to offset revenue losses and assist nursing homes with additional costs related to responding to the COVID-19 public health emergency (PHE) and the shipments of personal protective equipment (PPE) provided to nursing homes by the Federal Emergency Management Agency (FEMA). More details will be forthcoming on how those funds are going to be disbursed.
Provider Relief Fund Payments Subject to Single Audit Requirements
HHS recently added FAQs providing more guidance regarding the single audit requirements for providers receiving General and Targeted PRF distributions. These funds are to be included in calculating annual federal rewards for both Non-Profit and For-Profit entities. Certain funds received directly from state agencies may be also considered “federal awards” if the primary funding agency is a federal agency.
Non-Profit organizations that receive $750,000 or more in annual federal awards are required to have a single audit in accordance with 45 C.F.R. Part 75, Subpart F.
For-Profit commercial organizations that receive $750,000 or more in annual federal awards have two options:
- A financial audit conducted in accordance with Generally Accepted Government Auditing Standards (GAGAS) (45 CFR 75.216) or
- Single Audit in conformance with the requirements under 45 CFR 75 Subpart F.
The Office of Management and Budget (OMB) has provided certain flexibilities due to the COVID-19 pandemic, including the extension of time to submit audit reports
Medicaid Targeted Distribution Updates Deadline extended:
The application deadline for applying for the Medicaid, CHIP, and dentists targeted distributions has been extended to August 3, 2020. See our June 29, 2020 article for more details. In addition, HHS has scheduled a webcast on July 27, 2020, at 3:00 pm. Click here to pre-register.
The HHS guidance on the provider relief funds has been ever-changing and often conflicting. The FAQs continue to be updated frequently. HW&Co. is here to assist you in any way we can. Please visit the HW&Co. Current Events Center on our website for additional resources or contact your HW&Co. healthcare advisor if you need assistance.
Disclaimer: Information in this article is subject to change and is based upon our current understanding as of the issue date. This is a constantly evolving process as HHS has been issuing new or changed guidance on a frequent basis.
