Home Health & Hospice Week

Detailed reporting requirements out next month.

Change #1: When the Department of Health and Hu-man Services first announced Provider Relief Fund details in the spring, it indicated that in accordance with the CARES Act, providers receiving $150,000 or more in PRF funds would be required to submit quarterly reports (see Eli’s HCW, Vol. XXIX, No. 14). As recently as June 13 in its PRF Frequently Asked Questions, HHS stated that “the Terms and Conditions for all Provider Relief Fund payments require recipients who receive at least $150,000 in the aggregate from any statute primarily making appropriations for the coronavirus response to submit quarterly reports to HHS and the Pandemic Response Ac­countability Committee. This requirement is from section 15011 of the CARES Act.” The FAQ is still up on the HHS webpage.

Now, in a two-page notice posted July 20, HHS says the notice “is to inform Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000 in the aggregate from the PRF of the timing of future reporting requirements.”

“No explanation has been provided for requiring providers receiving less than the originally stated $150,000 to file reports,” notes consulting firm The Health Group in Morgantown, West Virginia, in its electronic newsletter.

The $10,000 benchmark applies to the payment total in the aggregate, notes the National Association for Home Care & Hospice. That implies that providers that returned their automatically distributed PRF payments — whether all or a portion that makes their total under $10,000 — will not have reporting duties.

Change #2: The CARES Act and HHS first announced quarterly reporting requirements, but the new notice makes it clear that providers must submit only one or possibly two reports, depending on timing.

“Last month, HHS clarified that it would not require quarterly reports," points out the American Hospital As­sociation. Many providers missed the quiet June 13 an­nouncement ahead of the July 10 quarterly reporting date (see Eli’s HCW, Vol. XXIX, No. 24).

But HHS didn’t announce what would take the place of the quarterly reporting structure.

Change #3: Now HHS has revealed the reporting date details. If a provider expends all of its funds by Dec. 31, 2020, it must submit one report that “demonstrate[s] compliance with the [Terms and Conditions], including use of funds for allowable purposes, for each PRF payment,” HHS explains in the new notice. Providers may start submitting reports as early as Oct. 1, but they are due by Feb. 15 — 45 days after the calendar year end.

In contrast, if a provider takes until next year to spend its PRF funds, it “must submit a second and final report no later than July 31, 2021,” HHS instructs.

That new information indicates a new deadline. “Based on these notices, it appears that providers must expend Provider Relief funds, in full, prior to submitting a final report by July 31, 2021,” advise attorney Aaron Cohen and Kate Broderick with accounting and advisory firm Citrin Cooperman in online analysis.

Stay tuned: HHS pledges to release “detailed instructions regarding these reports” by Aug. 17, according to the notice.

Prepare For Possible PRF Paybacks