After months of quiet soul-searching, on June 11, 2021, the US Department of Health and Human Services (HHS) released a long-awaited update Post-payment notification of reporting requirements, which describes updated reporting requirements on HHS Provider Relief Fund recipients. In addition, HHS released a series of news Faqs related to the reporting process.

Below are some of the most notable highlights from recent HHS guidelines.

New deadlines for using and reporting on the use of provider assistance funds

Recipients who have received one or more payments exceeding $ 10,000 in total during a “payment received period” are required to report in each “Reporting period” applicable. In other words, it appears that recipients cannot report during the July-September 2021 reference period for all supplier assistance funds received if some of these funds were received on or after the July 1, 2020. Relief funds depend on when the recipient received the funds, as shown below. Beneficiaries who do not present themselves within the respective declaration deadline will be considered as non-compliant with the general conditions of payment and the aid funds to the suppliers concerned may be reimbursed.

Period Payment period received
(Payments greater than $ 10,000 in aggregates received)
Reporting period
1 April 10, 2020 to June 30, 2020 July 1, 2021 to September 30, 2021
2 From July 1, 2020 to December 31, 2020 January 1, 2022 to March 31, 2022
3 January 1, 2021 to June 30, 2021 July 1, 2022 to September 30, 2022
4 July 1, 2021 to December 31, 2021 January 1, 2023 to March 31, 2023

The deadline for using Supplier relief funds for eligible COVID-19 expenses and losses (i.e., the “availability period” of funds) also depend on when funds were received, as noted below. below. Funds will be available for a minimum of 12 months and a maximum of 18 months, with payments considered “received” on the date of deposit for automated clearing house (ACH) payments or on the date the check is cashed. .

Period Payment period received Deadline for using funds
1 April 10, 2020 to June 30, 2020 June 30, 2021
2 From July 1, 2020 to December 31, 2020 December 31, 2021
3 January 1, 2021 to June 30, 2021 June 30, 2022
4 July 1, 2021 to December 31, 2021 December 31, 2022

Additional key tips

  • Parent entities can report on behalf of their subsidiaries with respect to any general distribution funds (i.e. phase 1, 2 or 3) received by the parent company or subsidiaries. However, the original recipient of any targeted distribution must report the use of the targeted distribution funds. This is necessary whether the parent company or subsidiary received payment from the targeted distribution or the original recipient subsequently transferred the payment. (Transferred targeted distribution payments face an increased likelihood of an audit.)
  • Reporting entities are expected to report on their use of provider relief funds using their normal accounting basis (eg cash or accrual) and submit consolidated reports.
  • Overall, the new reporting guidelines are more detailed than previous versions, detailing what subsidiary information should be reported, information relating to acquisitions and dispositions, and certain tax and audit information.
  • In the new guidelines, the HHS includes information on how recipients of SNF and Nursing Home Infection Control Distribution payments will report on these funds. The reporting mechanism will allow these beneficiaries to submit a consolidated report that distinguishes the use of SNF funds and distributions for infection control in nursing homes from other general and targeted distribution payments.
  • The burden of proof is on the reporting entity to ensure that it maintains adequate documentation indicating that funds were used for healthcare-related expenses or loss of income attributable to COVID-19, and that these expenses or losses have not been reimbursed (or obligated to be) reimbursed by) other sources.
  • If a beneficiary does not have enough expenses or losses attributable to COVID-19 to support the funds received, the funds must be returned to HHS. The HHS says beneficiaries will be able to return unused funds through the reporting portal when the first reporting period begins on July 1, 2021.

We will continue to monitor updates on Supplier Emergency Fund guidelines and reporting timelines and provide additional updates as they are released.

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