ISSUE 142, Special Section: Cancer Care

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Update on Provider Relief Funds and Their Audit Requirements

The Health Resources and Services Administration (HRSA) announced two important updates last week related to Provider Relief Funds (PRF) and reporting requirements:

1. An additional $25.5 billion of PRF distributions

$8.5 billion for providers that serve rural patients under the Medicare, Medicaid or Children’s Health Insurance Program (CHIP), and
$17 billion “for a broad range of providers who can document revenue loss and expenses associated with the pandemic.”

2. A 60-day grace period for meeting PRF reporting requirements

Implemented in order to help providers comply with PRF reporting requirements
Although HHS will not initiate collection activities or enforcement actions during the grace period, providers will still be out of compliance if reporting is not submitted by September 30, 2021

The new guidance released a few weeks ago clarifies that entities with fiscal years ending June 30, 2021 will be the first entities required to include Provider Relief Funds on their Schedule of Expenditure of Federal Awards (SEFA) and thus, be subject to audit of these funds. Entities with other fiscal year ends will include some or all of their Provider Relief Funds on their next fiscal year end.

For example, if you are a December 31, 2021 year end, then you will include all funds from Periods 1 and 2 (described above) in your SEFA and your December 31, 2022 SEFA will include periods 3 and 4. Below are the specific FAQs that were released by HHS.

When should Provider Relief Fund expenditures and/or lost revenue be reported on a nonfederal entity’s Schedule of Expenditures of Federal Awards (SEFA)?

Non-federal entities will include Provider Relief Fund expenditures and/or lost revenues on their SEFAs for fiscal year ends (FYEs) ending on or after June 30, 2021. Please refer to the 2021 OMB Compliance Supplement for additional information.

How will a non-federal entity determine the amount of expenditures and/or lost revenues to report on its SEFA for FYEs ending on or after June 30, 2021?

A non-federal entity’s SEFA reporting is linked to its report submissions to the Provider Relief Fund Reporting Portal. Therefore, the timing of SEFA reporting of Provider Relief Fund payments will be as follows:

For a FYE of June 30, 2021, and through FYEs of December 30, 2021, recipients are to report on the SEFA the total expenditures and/or lost revenues from the Period 1 report submission to the Provider Relief Fund Reporting Portal.

For a FYE of December 31, 2021, and through FYEs of June 29, 2022, recipients are to report on the SEFA, the total expenditures and/or lost revenues from both the Period 1 and Period 2 report submissions to the Reporting Portal.

For FYEs on or after June 30, 2022, SEFA reporting guidance related to Period 3 and Period 4 will be provided at a later date.

As discussed in the FAQs above, we will need to wait for the FY2021 OMB Compliance Supplement to be released later this summer for more information.

If you have questions about these updates or requirements, please reach out to us for more information at lmann@deandorton.com 502.566.1005 or visit deandorton.com.