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HHS announces Provider Relief Fund reporting requirements

Guidance directed to providers who received $10,000 or more in funding

September 22, 2020

By Jennifer Garvin

Washington — The U.S. Department of Health and Human Services released guidance Sept. 19 outlining reporting requirements for health care providers who received funding from the Provider Relief Fund.

The HHS Provider Relief Fund was established by the Coronavirus Aid, Relief and Economic Security Act to reimburse eligible providers for health care related expenses or lost revenue as a result of the COVID-19 pandemic. According to HHS, recipients who received one or more payments over $10,000 will be required to comply with the requirements when the reporting system opens in early 2021.

The ADA has updated its Provider Relief Fund FAQ to help dentists comply with the reporting requirements.

Highlights from the new HHS guidance include:

• Recipients are required to submit all health care-related expenses attributed to COVID-19 that “another source has not reimbursed and is not obligated to reimburse,” which may include general and administrative expenses such as mortgage or rent, insurance premiums, hazard pay and equipment leases. Operating expenses attributable to the pandemic could include personal protective equipment and other supply purchases, updates to HVAC systems and IT updates.
• Provider Relief Fund payments not fully expended on health care-related expenses attributable to COVID-19 “will be applied to lost revenues and represented as a negative change in the provider’s net patient care operating income,” the department said. “Recipients may apply relief payments toward lost revenue, up to the amount of their 2019 net gain from health care-related sources” and “recipients who reported negative net operating income from patient care in 2019 may apply relief fund amounts to lost revenues up to a net zero gain/loss in 2020.”
• If recipients do not expect PRF funds in full by the end of 2020, HHS said they will have “an additional six months in which to use remaining amounts toward expenses or lost revenues in an amount not to exceed the 2019 net gain.”
• Regarding auditing, the ADA FAQ points out that “while HHS stipulates that every payment made to providers from the PRF may be subject to an audit, those entities that expended $750,000 or more in aggregated federal financial assistance in 2020” (including relief payments and other federal financial assistance) are “subject to Single Audit requirements.” HHS also said “recipients must indicate if they are subject to Single Audit requirements in 2020 and if yes, whether the auditors selected PRF payments to be within the scope of the Single Audit (if known at the time the Reporting Entity submits report.)" The ADA also noted that all recipients of PRF payments should also maintain appropriate records and cost documentation.

For dentists who received less than $10,000, the ADA has reached out to HHS for clarification on the guidance.

For more information, visit the Terms and Conditions tab on the provider instructions for the HHS CARES Act Provider Relief Fund.

For real-time support, HHS has established a provider support line at 1-866-569-3522. The hours of operation are 7 a.m.-10 p.m. Central, Monday – Friday.

For more information about the ADA’s advocacy efforts during COVID-19, visit ADA.org/COVID19Advocacy.