The Provider Relief Fund (PRF), originally created under the CARES Act to help nonprofit and for-profit healthcare providers respond to the COVID-19 health crisis, brought new compliance obligations for recipients of more than $10,000 in PRF payments. After announcing the reporting requirements last fall and opening the portal for registration in January, HHS quickly put the deadline on hold.
Following months of silence, HHS has finally released revised requirements and timelines for reporting PRF payments. Highlights of the changes include:
- Providers can begin submitting their reports on July 1, 2021.
- Recipients must report for every period in which they received $10,000 or more in the aggregate.
- Skilled nursing facilities are subject to an additional infection control reporting requirement.
- Deadlines to use and report funds are now based on the date payment was received.
Under the revised requirements, providers have a year after the end of the payment received period to use the PRF funds received during that period. If the amount totaled more than $10,000, the deadline to report is three months after the end of the payment received period. For example, for payments received during Period 1 (April 10 to June 30, 2020), the deadline to use the funds is June 30, 2021, and the reporting period is July 1 to September 30, 2021.
Providers who received other forms of federal funding should take a comprehensive look at their spending to ensure their reporting is in compliance with all program requirements. PRF payments that are allocated to the same expenses as other federal funding would constitute double dipping. In addition, if the PRF funding puts the provider over $750,000 in federal payments received, a single audit would be required for both nonprofit and for-profit providers.
Careful consultation with your CPA and nonprofit advisors will help you manage and keep the relief your organization deserves. Contact David M. Rottkamp, Grassi’s Not-for-Profit Leader, at drottkamp@grassiadvisors.com to learn more.
This article originally appeared in the July 2021 edition of the BBB Foundation newsletter.
