On Friday, June 11, the Department of Health and Human Services (“HHS”) released a revised Post-Payment Notice of Reporting Requirements. The new version supersedes all previous versions of the Post-Payment Notice of Reporting Requirements documents.

Key updates are included below:

  • Previous guidance required all funds to be used by June 30, 2021. The deadline to use funds is now dependent on when the funds were received (see table below).
  • Reporting is required for each Payment Received Period in which an entity received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all provider relief fund (“PRF”) payments).
  • Recipients have a 90-day period to complete reporting (see table below). Previous guidance included a 30-day period.
  • Skilled Nursing Facility and Nursing Home Infection Control Distribution are now subject to the reporting requirements, in addition to General and other Targeted Distributions.
  • The PRF Reporting Portal will open for providers to begin submitting information on July 1, 2021.

The table summarizes the use and reporting requirements.
The table summarizes the use and reporting requirements.

Providers that fail to report within the respective reporting period are considered out of compliance with the payment Terms and Conditions, and funds may be subject to recoupment. The Health Resources and Services Administration (“HRSA”) plans to hold webinars to provide further guidance and assistance navigating the PRF Reporting Portal. HHS has also posted some additional Frequently Asked Questions which are included at the link.

Ensure your organization is ready.

  • Register in the PRF Reporting Portal, if you have not already done so. For payments received in April through June 2020, the portal will open July 1 and reporting will close September 30, 2021. Click here to register. This will ensure you receive information on upcoming HRSA webinars.
  • Begin accumulating the required reporting information. Click here for full Post-Payment Notice of Reporting Requirements, including data required to be included with submission.

We expect additional guidance to be released regarding testing of the reporting requirements for Single Audits and further clarification on the financial related audits for commercial entities.