The US Department of Health & Human Services (HHS) updated the frequently asked questions (FAQs) on June 13, 2020, about reporting requirements for the Coronavirus Aid, Relief, and Economic Security (CARES) Act Provider Relief Fund recipients.
A previous HHS FAQ referenced the quarterly reporting requirement, which was originally due on July 10, 2020. This FAQ has now been deleted.
New HHS Report to Come
The new FAQ informally communicates providers who received CARES Act Provider Relief Fund payments won’t need to file their first quarterly compliance report.
Further Guidance Anticipated
Instead, HHS has indicated it will develop its own report; this report will contain “all information necessary for recipients of Provider Relief Fund payments to comply with” the quarterly reporting requirements under the CARES Act Provider Relief Fund Terms and Conditions.
The reprieve is only temporary. Although HHS notified providers the first quarterly report wasn’t due, they did remind entities of their obligation to adhere to the Terms and Conditions, which “require recipients to submit any reports requested by [HHS] that are necessary to allow HHS to ensure compliance with [the] payment Terms and Conditions.”
It’s also important to note that HHS will be notifying “recipients of the content and due dates of such reports in the coming weeks.”
HRSA Reporting Deadlines
Some health care entities received funds from the Health Resources and Services Administrations (HRSA) instead of directly from HHS. Although HHS deleted the FAQ about the first quarterly report due date, the due date hasn’t changed for those health centers entities who received Provider Relief funds through HRSA. The HRSA FAQ posted on June 1, 2020, has a submission due date of July 10, 2020, through the HRSA Electronic Handbooks (EHB).
Until there’s guidance and dates, providers should continue to carry out the Terms and Conditions and maintain detailed documentation on the proper use of their Relief Fund payments.
Such documentation will be critical to demonstrating compliance and completing the future reports required by HHS.
To learn more around best practices for proper tracking and compliance, please read our article How to Track COVID-19-Related Expenses and Lost Revenue for Funding Compliance.
We’re Here to Help
If you have any questions regarding HHS or HRSA deadlines, please contact 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: