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Reminder - HHS Stimulus Grace Period Ending November 30, 2021

By Kate Broderick .

The grace period for completing the reporting requirements for Provider Relief Fund (HHS Stimulus) payments received before June 30, 2020 ends November 30, 2021. Nearly ALL healthcare providers received this funding and are required to meet reporting requirements — including nursing homes, durable medical equipment providers, physical therapists, and pharmacies. The original deadline for reporting on Provider Relief Fund payments received before June 30, 2020 was September 30, 2021; if you have already completed reporting, please disregard.

If the reporting requirements are not met, providers will be considered out of compliance with the terms & conditions and subject to enforcement action from HHS, including recoupment of the funds.

Our team has worked with many clients on reporting for these funds and can provide support. However, please note that the reporting requirements are detailed, and you may miss the deadline if the work is left to the last minute. If you require assistance or you are unsure if you received a payment, please reach out and we can help you to confirm and develop a plan for completing reporting.

What is the Provider Relief Fund (“PRF”)? 
The PRF is a stimulus program created through the CARES Act for healthcare providers. The funds can be used for increased healthcare related expenses and lost revenues due to coronavirus. Some providers received significant payments through this program. 

Who received it? 
Almost all healthcare providers, including ancillary providers such as physical therapists, labs, pharmacies, and durable medical equipment providers. 

When was it received?
All Medicare providers received an automatic distribution on April 10, 2020. Since then, providers may have received additional funds through applications.

What are the reporting requirements?
Providers must report on their use of the funds, other assistance they received from programs like the PPP, and personnel and patient metrics. While the requirements may sound simple, some providers may face challenges in tracking down the necessary information.

What happens if the reporting requirements are not met?
If the provider does not meet the reporting requirements, they will be considered out of compliance with the terms and conditions of the program. At present, the understanding is that the provider would be subject to a recoupment process from HHS, requiring them to return the funds. It is unclear at this point if they will face additional enforcement action from HHS. 

If you have any questions, please contact Kate Broderick at kbroderick@citrincooperman.com.

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