Previously, the U.S. Department of Health and Human Services (“HHS”) issued Notice of Reporting Requirements relating to the use of Provider Relief Funds. HHS informed providers that forms would be available in mid-August 2020 and would be required for all providers that received payments exceeding $10,000.
On August 14, 2020, HHS issued General and Targeted Distribution Post-Payment Notice of Reporting Requirements, which effectively informed providers that forms were not ready but that the reports and any associated instructions would be released soon.
These reporting instructions will provide directions on reporting obligations applicable to any provider that received a payment from the following:
- General Distributions:
- Initial Medicare Distribution,
- Additional Medicare Distribution, and
- Medicaid, Dental & CHIP Distribution.
- Targeted Distributions:
- High Impact Area Distribution,
- Rural Distribution,
- Skilled Nursing Facilities Distribution,
- Indian Health Service Distribution, and
- Safety Net Hospital Distribution.
HHS also provided a summary of the timing for report submission as follows:
The reporting system will become available to recipients for reporting on October 1, 2020.
- All recipients must report within 45 days of the end of calendar year 2020 on their expenditures through the period ending December 31, 2020.
- Recipients who have expended funds in full prior to December 31, 2020 may submit a single final report at any time during the window that begins October 1, 2020, but no later than February 15, 2021.
- Recipients with funds unexpended after December 31, 2020, must submit a second and final report no later than July 31, 2021.
No forms or instructions have been provided as of today. While most providers are pleased that no submissions are required as of now, the lack of a reporting format and instructions is concerning given that providers have little guidance in what will be expected when reporting is required. We encourage providers to aggressively identify and document all expenses incurred due to the COVID-19 PHE as well as revenues which may have been lost due to the COVID-19 PHE. Providers can always reduce expenses and lost revenues based on any ultimate guidance provided; however, they may not be able to reconstruct expenses or lost revenues after-the-fact.
We will constantly monitor the status of HHS reporting and provide detailed guidance once reporting formats have been released.