Without announcement or notice, the U.S. Department of Health and Human Services (HHS) notified Monday, July 20, 2020, that providers who have received a total of $10,000 or more in Provider Relief Fund (PRF) payments now have a looming reporting deadline of February 15, 2021. Detailed reporting instructions will be issued by August 17, 2020.
If you received a payment from the General Distribution (including the $30 billion tranche, the $20 billion tranche, or Medicaid, Dental & CHIP allocation) or a Targeted Distribution this applies to you.
Remember, HHS previously announced that PRF recipients were not required to submit quarterly reports to HHS or the Pandemic Response Accountability Committee. HHS has revised that guidance. Here are the key dates:
- August 17, 2020 – Detailed reporting instructions will be released
- October 1, 2020 – Reporting system will become available
- February 15, 2021 – By this date, recipients must report on their expenditures through December 31, 2020
- July 31, 2021 – By this date, recipients with unexpended funds following December 31, 2020, must submit a second and final report on their expenditures
There is one ambiguity worth mentioning here. Since HHS’ notice provides that recipients with unexpended funds following December 31, 2020, must submit a “second and final report” by July 31, 2021, there is speculation that July 31, 2021, may be the final deadline for all PRF distributions to be used or returned to HHS. We expect future guidance from HHS to clarify this issue.
HHS also explained that its Health Resources and Services Administration will offer Q&A sessions via webinars in advance of the submission deadlines—additional details regarding these sessions will follow.
