Important note: Legislation and guidance on this topic are constantly evolving. Information is current as of date of publication.
The required financial data reporting deadline is today, June 3, 2020, for recipients of the general distribution payments made by the US Department of Health and Human Services on April 10, April 17, and April 24, 2020.
Requirements are below.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act and subsequent Paycheck Protection Program and Health Care Enhancement Act, which is also known as CARES 3.5, allocated $175 billion to the Provider Relief Fund.
Of this, a general distribution of $50 billion was allocated to hospitals and eligible providers to compensate for COVID-19-related expenses and lost revenue. Over $27 billion was distributed via targeted allocations to high impact areas, rural providers, skilled nursing facilities (SNFs), and tribal providers.
An unspecified amount is available for reimbursement of uninsured patients’ testing and treatment at Medicare rates, via a claims-based application.
To Complete Reporting for General Distribution
According to HHS, health care providers must:
- Confirm receipt of previous funds on the Payment Attestation Portal, including agreeing to the Terms and Conditions, prior to submitting financial data. Carefully review the Terms and Conditions and consider consulting with legal counsel to confirm your entity can comply.
- Submit revenue information to the Financial Data Portal, which includes gross receipts, sales, or program service revenue from the most recently filed tax return or audited financial statements for tax-exempt entities, as well as an estimate of lost revenue for March 2020 and April 2020.
Single Audit Requirement
The Health Resources and Services Administration (HRSA) declared on SAM.gov, that the Provider Relief Fund and Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 are subject to the provisions of 2 CFR 200, Subpart F – Audit Requirements.
This effectively subjects nonfederal entities, subject to 2 CFR 200 Subpart F that expend $750,000 or more of federal expenditures, to single audit or program-specific audit requirements.
The provisions of Subparts B, D, and E of 2 CFR 200 are applicable to the Provider Relief Fund, whereas, Subpart C of 2 CFR 200 is not applicable, according to SAM.gov. The provisions of Subparts B, C, D, and E of 2 CFR 200 are applicable to the Emergency Grants to Address Mental and Substance Use Disorders.
This begins to clarify the requirements that organizations must comply with for the programs and what auditors will test as part of the single audit. Additional guidance hasn’t been released on what qualifies as a health care-related expense attributable to COVID-19 or what qualifies as lost revenue in relation to the Provider Relief Fund.
We’re Here to Help
If you need any assistance with accessing the Provider Relief Fund reporting portal, determining the dollar-amounts to report, or preparing your documentation and policies for an audit, please reach out to your Moss Adams professional.
For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources: