Many chiropractors in Kentucky received funds from the federal government under the Provider Relief Fund (PRF) program. As a reminder, this program had three primary phases, and the first phase happened without any action on the provider’s part (i.e. the money appeared in the provider’s account).

In addition to the attestations and applications required along the way of the three-payment program, there is also a reporting requirement for some providers. The reporting opened July 1, 2021 and providers should complete the report based on the “Payment Received Period” by the “Reporting Time Period” deadline.

In short, only providers who received greater than $10,000 in any reporting period must report for that period. See the chart below to see the Payment Received Period. If you received $10,000 or more for any of those periods, you would be required to report for that period.

Summary of Reporting Requirements

 Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)Deadline to Use FundsReporting Time Period
Period 1From April 10, 2020 to June 30, 2020June 30, 2021July 1 to September 30, 2021
Period 2From July 1, 2020 to December 31, 2020December 31, 2021January 1 to March 31, 2022
Period 3From January 1, 2021 to June 30, 2021June 30, 2022July 1 to September 30, 2022
Period 4From July 1, 2021 to December 31, 2021December 31, 2022January 1 to March 31, 2023
Source: https://www.hhs.gov/about/news/2021/06/11/hhs-issues-revised-reporting-requirements-timeline-for-provider-relief-fund-recipients.html

HOW SHOULD FUNDS BE USED?

According to HHS, the PRF funds should “be used to prevent, prepare for, and respond to coronavirus. Provider Relief Fund payments may also be used for lost revenues attributable to the coronavirus.” Additionally, they should not have been “reimbursed from other sources and other sources were not obligated to reimburse them.” This means that if you attributed funds for a PPP loan or another grant program reimbursed for expenses, then they would NOT be eligible to be included for PRF reporting.

HHS went further to provide examples: “Expenses attributable to coronavirus may include items such as supplies, equipment, information technology, facilities, personnel, and other healthcare-related costs/expenses for the period of availability.”

Interestingly, HHS also deems as eligible expenses the taxes that you paid on the PRF amounts.

Also, HHS allows for funds to offset a loss in revenue. This means if your revenues are lower in a given reporting period in 2020 vs. the same period in 2019, the funds can be used for offsetting that reduction. In addition, any unused portion of lost revenue for an earlier period can be carried forward to a future reporting period.

WHAT ABOUT DOCUMENTATION?

HHS states, “Reporting Entities are not required to submit that documentation when reporting. Providers are required to maintain supporting documentation which demonstrates that costs were obligated/incurred during the period of availability. The burden of proof is on the Reporting Entity to ensure that adequate documentation is maintained.”

NEXT BEST STEPS

  1. Make a list of all PRF payments you received and the dates (many of these funds were distributed by UHC and labeled with HHS).
  2. If the total amount of PRF received during any period is greater than $10,000, then:
    • Determine lost revenues during the reporting period,
    • Determine eligible expenses,
    • Complete the Report during the Reporting Time Period listed in the chart above.
    • Make a permanent file to maintain all reporting determinations, as HHS requires.

As of the morning of July 1, 2021, the Health and Human Services (HHS) Provider Relief Fund (PRF) Reporting Portal is open.


Sources:

HHS Issues Revised Notice of Reporting Requirements and Reporting Timeline for Recipients of Provider Relief Fund Payments: https://www.hhs.gov/about/news/2021/06/11/hhs-issues-revised-reporting-requirements-timeline-for-provider-relief-fund-recipients.html

Reporting Requirements and Auditing https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html