Provider Relief Fund Update

On July 20, the U.S. Department of Health and Human Services (HHS) issued an update regarding the required future reporting for the Provider Relief Fund. As part of the update, HHS clarified that all providers that have received one or more payments from the Provider Relief Fund, exceeding $10,000 in aggregate, will be subject to such future reporting requirements. HHS noted that detailed instructions would be issued for the reporting requirements by August 17, 2020.

In addition, HHS provided some additional clarification on the timing of reporting:

• The reporting system will become available on October 1, 2020.
• All recipients must report within 45 days of the end of the calendar year 2020 on their expenditures through the period ending December 31, 2020.
• Recipients who have expended funds in full prior to December 31, 2020 may submit a single final report at any time during the window that begins October 1, 2020 but no later than February 15, 2021.
• Recipients with funds unexpended after December 31, 2020 must submit a second and final report, no later than July 31, 2021.
• Detailed Provider Relief Fund reporting instructions and a data collection template with the necessary data elements will be available through the HRSA website by August 17, 2020.

Importantly, based on these notices, it appears that providers must expend Provider Relief funds, in full, prior to submitting a final report by July 31, 2021.

For more information, please contact your Citrin Cooperman professional or a member of our healthcare practice listed below.

Aaron Cohen, JD, MPhil Principal, Healthcare Co-Practice Leader acohen@citrincooperman.com	Kate Broderick, MBA/MSIS Manager kbroderick@citrincooperman.com