Reporting Requirements and Auditing

All recipients of Provider Relief Fund (PRF) payments must comply with the reporting requirements described in the Terms and Conditions and specified in directions issued by the Secretary.

Update: The PRF Reporting Portal is now open for recipients who are required to report during Reporting Period 1. PRF recipients may use payments for eligible expenses and lost revenues to prevent, prepare for, and respond to coronavirus.

HRSA will host recorded Reporting Technical Assistance Sessions to provide technical assistance on reporting requirements for PRF recipients and stakeholders:

  • July 14, 2021 at 3 PM ET
  • July 20, 2021 at 3 PM ET (Register here)

HRSA hosted a webinar on July 8, 2021 to give providers and stakeholders an introduction to the PRF Reporting Portal.

Getting Started

Review the updated Reporting Requirements Notice (June 11) and enter the PRF Reporting Portal. Portal registration is the first required step (if not already completed).

Reporting Resources

HHS revised the Post-Payment Notice of Reporting Requirements* as of June 11, 2021, which superseded all previous versions of the Post-Payment Notice of Reporting Requirements documents. Key updates made in the June 11th Notice:

  • The period of availability of funds is based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received).
  • Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).
  • Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period).
  • The reporting requirements are now applicable to recipients of the Nursing Home Infection Control Distribution (formally called the Skilled Nursing Facility and Nursing Home Infection Control Distribution) in addition to General and other Targeted Distributions.

Summary of Reporting Requirements

  Payment Received Period (Payments Exceeding $10,000 in Aggregate Received) Deadline to Use Funds Reporting Time Period
Period 1 From April 10, 2020 to June 30, 2020 June 30, 2021 July 1 to September 30, 2021
Period 2 From July 1, 2020 to December 31, 2020 December 31, 2021 January 1 to March 31, 2022
Period 3 From January 1, 2021 to June 30, 2021 June 30, 2022 July 1 to September 30, 2022
Period 4 From July 1, 2021 to December 31, 2021 December 31, 2022 January 1 to March 31, 2023

Recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report in each applicable Reporting Time Period as outlined in the table above. 

Providers are encouraged to register in the PRF Reporting Portal in advance of the relevant Reporting Time Period dates. The registration process will take approximately 20 minutes to complete and must be completed in one session. The entire registration form must be completed for it to be saved.

These reporting requirements will not apply to recipients of funds from:

Period of Availability and Reporting Time Periods

Period of Availability (Updated June 2021)

The period of availability of funds and reporting time period applies to all past and future PRF payments.

Provider Relief Fund recipients must only use payments for eligible expenses, including services rendered, and lost revenues attributable to coronavirus before the deadline that corresponds to the relevant Payment Received Period. These deadlines are based on the date the payments are received, as indicated in the table below – all funds will be available for at least 12 months and a maximum of 18 months. The payment is considered received on the deposit date for automated clearing house (ACH) payments or the check cashed date.  Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.

Deadlines for Use of Funds

  Payment Received Period Deadline to Use Funds
Period 1 Payments received April 10, 2020 to June 30, 2020 June 30, 2021
Period 2 Payments received July 1, 2020 to December 31, 2020 December 31, 2021
Period 3 Payments received January 1, 2021 to June 30, 2021 June 30, 2022
Period 4 Payments received July 1, 2021 to December 31, 2021 December 31, 2022

PRF recipients may use payments for eligible expenses or lost revenue incurred prior to receipt of those payments (i.e., pre-award costs) so long as they are to prevent, prepare for, and respond to coronavirus.  However, HHS expects that it would be highly unusual for providers to have incurred eligible expenses prior to January 1, 2020.  All recipients are subject to audit. 

Reporting Time Periods (Updated June 2021)

Provider Relief Fund recipients are required to report in each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000, as indicated in the table below. Reporting must be completed and submitted to HRSA by the last date of the reporting time period. Provider Relief Fund recipients that do not report within the respective reporting time period are out of compliance with payment Terms and Conditions and funds may be subject to recoupment.

  Payment Received Period (Payments Exceeding $10,000 in Aggregate Received) Reporting Time Period
Period 1 Payments received April 10, 2020 to June 30, 2020 July 1, 2021 to Sept 30, 2021
Period 2 Payments received July 1, 2020 to December 31, 2020 January 1, 2022 to March 31, 2022
Period 3 Payments received January 1, 2021 to June 30, 2021 July 1, 2022 to Sept 30, 2022
Period 4 Payments received July 1, 2021 to December 31, 2021 January 1, 2023 to March 31, 2023

Details about Reporting Requirements

To be an allowable expense under the PRF, the expense must be used to prevent, prepare for and respond to coronavirus. All expenses need to be supported by adequate documentation. Providers are required to maintain documents to substantiate that these funds were used for health care-related expenses or lost revenues attributable to coronavirus, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them. The burden of proof is on the provider to ensure that documentation is maintained to show that expenses are to prevent, prepare for and respond to coronavirus.  Read examples of allowable expenses for Provider Relief Funds for more information.

What are the categories of data required for reporting?

  • Reporting Entity Business Information
  • Subsidiary Questionnaire
  • Acquired/Divested Subsidiaries
  • Interest Earned on PRF Payment(s)
  • Tax and Single Audit Information
  • Other Assistance Received
  • Use of General and Targeted Distribution (including Skilled Nursing Facility and Nursing Home Infection Control Distribution) Payment(s)
  • Unreimbursed Expenses Attributable to Coronavirus
  • Lost Revenues Attributable to Coronavirus (and additional revenue information depending upon the option selected to calculate lost revenues)
  • Personnel, Patient, and Facility Metrics
  • Survey Questions

Auditing

Recipients that expend a total of $750,000 or more in federal funds (including PRF payments and other federal financial assistance) during their fiscal year are subject to Single Audit requirements, as set forth in the regulations at 45 CFR 75 Subpart F.

Non-federal entities must have a Single Audit conducted in accordance with 45 CFR 75.514 that must be submitted electronically to the Federal Audit Clearinghouse.

Commercial organizations have two options under 45 CFR 75.216(d) and 75.501(i): 1) a financial related audit of the award or awards conducted in accordance with Generally Accepted Government Auditing Standards; or 2) an audit in conformance with the requirements of 45 CFR 75.514 - Single Audit). Audit reports of commercial organizations must be submitted via email to HRSA’s Division of Financial Integrity at PRFaudits@hrsa.gov.

The recipients of PRF payments may be subject to additional auditing to ensure the accuracy of the data submitted to HHS for payment. Any recipients identified as having provided inaccurate information to HHS will be subject to payment recoupment and other legal action. Further, all recipients of PRF payments shall maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR § 75.302 – Financial management and 45 CFR § 75.361 through 75.365 – Record Retention and Access, and other information required by future program instructions to substantiate that recipients used all Provider Relief Fund payments appropriately.

Upon the request of the Secretary, the recipient shall promptly submit copies of such records and cost documentation and the recipient must fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with applicable Terms and Conditions. Deliberate omission, misrepresentation, or falsification of any information contained in payment applications or future reports may be punishable by criminal, civil, or administrative penalties, including but not limited to revocation of Medicare billing privileges, exclusion from federal health care programs, and/or the imposition of fines, civil damages, and/or imprisonment.

For more details, please refer to the Terms and Conditions associated with each payment distribution and the Reporting Requirements and Auditing FAQs.

*This content is in the process of Section 508 review. If you need immediate assistance accessing this content, please submit a request to digital@hhs.gov. Content will be updated pending the outcome of the Section 508 review.

Content created by Assistant Secretary for Public Affairs (ASPA)
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