Reporting and Auditing Questions

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Auditing and Reporting Requirements

Use of Funds

Calculating Eligible Expenses and Lost Revenue

Supporting Data

Change of Ownership

Non-Financial Data

Extensions

Miscellaneous

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Reporting and Auditing Questions

Auditing and Reporting Requirements

Do commercial organizations that do not submit their audit through the Federal Audit Clearinghouse get an extension to the submission due date for their audit?

A non-profit corporation has multiple subsidiaries, including a for-profit subsidiary, that are consolidated for financial reporting purposes. Can the Single Audit of the non-profit corporation include the expenditures of federal awards of the for-profit subsidiary?

When should Provider Relief Fund expenditures and/or lost revenue be reported on a for-profit entity’s Schedule of Expenditures of Federal Awards (SEFA) or other schedules prepared for the financial-related audit option conducted in accordance with Government Auditing Standards?

How will a for-profit entity determine the amount of expenditures and/or lost revenues to report on its SEFA or other schedules prepared for the financial-related audit option conducted in accordance with Government Auditing Standards (for FYEs ending on or after June 30, 2021)?

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

Can my organization get an extension to the submission due date for Single Audits conducted under 45 CFR Part 75?

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?

Will HHS release separate requirements for recipients of the Skilled Nursing Facility (SNF)and Nursing Home Infection Control Distribution payments?

Will HHS provide guidance to certified public accountants and those organizations that providers will rely on to perform audits?

Are Provider Relief Fund payments to commercial (for-profit) organizations subject to Single Audit in conformance with the requirements under 45 CFR 75 Subpart F?

The Rural Health Clinic (RHC) COVID-19 Testing Program requires that recipients report payments received separately from the payment(s) received as part of the Provider Relief Fund. How do RHCs determine whether they received payment as part of the RHC COVID-19 Testing Program?

Are Provider Relief Fund payments to non-Federal entities (states, local governments, Indian tribes, institutions of higher education, and nonprofit organizations) subject to Single Audit?

Use of Funds

Must HRSA Health Center Program-funded health centers and look-alikes fully draw down Health Center Program COVID-19 Supplemental grant funding received from HRSA before using Provider Relief Fund payments for eligible expenses and lost revenues attributable to coronavirus?

How does a Reporting Entity determine whether an expense is eligible for reimbursement through the Provider Relief Fund?

Can providers include the entire cost of capital facilities projects as eligible expenses, or will eligible expenses be limited to the depreciation expense for the period?

If rent or mortgages were paid during the applicable period of availability but staff worked remotely, could those expenses be claimed as eligible expenses?

If a Reporting Entity anticipates that it will receive coronavirus-related assistance, such as from FEMA, but that assistance has not yet been received, should that be accounted for in its Provider Relief Fund reporting?

Must the Reporting Entity be in receipt of purchases made using Provider Relief Fund Payments in order for the expense to be considered eligible for reimbursement?

Can providers allocate parent overhead costs to the entities that received CARES Act Provider Relief Funds?

How do I determine if expenses should be considered “expenses attributable to coronavirus not reimbursed by other sources?”

How does cost-based reimbursement relate to my Provider Relief Fund payment?

Can Reporting Entities claim the time spent by staff and director-level resources on COVID-19-specific matters, such as participating in task forces or preparing their health care organization’s COVID-19 response, that they would not have otherwise spent time on in the absence of the pandemic?

Are there any restrictions on how hospitals that receive Medicaid disproportionate share hospital (DSH) payments can use Provider Relief Fund General and Targeted Distribution payments?

Is interest earned on Provider Relief Fund funds considered a reportable revenue source to HHS?

Are expenses related to securing and maintaining adequate personnel reimbursable expenses under the Provider Relief Fund?

Are outsourced or third-party vendor services that enable access to health care services reimbursable expenses under the Provider Relief Fund?

Can providers use Provider Relief Fund payment to pay taxes?

Do providers report total purchase price of capital equipment or only the depreciated value?

Will the Provider Relief Fund limit qualifying expenses for capital equipment purchases to 1.5 years of depreciation, or can providers fully expense capital equipment purchases?

What is included in use of funds for salaries and employee compensation?

Are fringe benefits for both patient care staff and General and Administrative (G&A) staff considered Provider Relief Fund eligible expenses under the "expenses attributable to coronavirus not reimbursed by other sources"?

If a provider received Provider Relief Fund payments and ARP Rural payments, can they use these payments for the same eligible expenses or lost revenues?

Calculating Eligible Expenses and Lost Revenue

Can a Reporting Entity use a different lost revenues methodology for each reporting period?

In subsequent reporting periods, will Reporting Entities be able to change the lost revenues methodology used in a previous reporting period?

In a previous reporting period, a Reporting Entity reported lost revenues that were greater than the PRF payments it received. How will the system account for the unused lost revenues previously reported?

Could choosing a different methodology from one reporting period to another result in having unused funds to return because the method to calculate lost revenues has now changed?

What happens when a Reporting Entity changes the lost revenues methodology from one reporting period to the next?

Can Nursing Home Infection Control payments be used to reimburse lost revenues attributable to coronavirus?

If a nursing home or skilled nursing facility received Nursing Home Infection Control Distribution payments in addition to General Distribution payments and other Targeted Distribution payments, how may these payments be applied toward expenses and lost revenues?

When completing a report, are Reporting Entities required to submit documentation to support Nursing Home Infection Control Distribution expenses?

How should providers that require separate reporting on behalf of parent entities and/or subsidiaries calculate lost revenue across these entities?

Should grants awarded to FQHCs under the Health Center Program and COVID-specific grants to FQHC Look-Alikes be factored into the lost revenue calculation?

How will HRSA calculate lost revenues for providers that select Option i (Comparison of Actual Lost Revenues) at the time of reporting?

How will HRSA calculate lost revenues for providers that select Option ii (Comparison of Budgeted to Actual Lost Revenues) at the time of reporting?

When reporting on lost revenues, how should Reporting Entities treat “contractual adjustments from all third party payers” and “charity care adjustments” when determining patient care-related revenue sources?

What is the maximum allotment of my organization’s Provider Relief Fund amount that can be allocated to lost revenues during the period of availability of funds?

What is the baseline comparison period for providers that report on patient care revenue using Option i (Comparison of Actual Lost Revenues) or Option ii (Comparison of Budgeted to Actual Lost Revenues)?

Can recipients use 2020 budgeted revenues as a basis for reporting lost revenues?

How will HRSA use “Other Assistance Received” when calculating expenses or lost revenues?

How will HRSA use the net unreimbursed expenses attributable to coronavirus in the calculation of expenses or lost revenues?

Will patient care revenue be counted against a Reporting Entity twice if the entity reported in “Other Assistance Received” and in the “Patient Care/Lost Revenue” sections of the Reporting Portal?

Reporting Entities have varying fiscal year ends (e.g., June 30, September 30, or December 31). How should providers report lost revenues if their fiscal year does not align with the calendar year?

If a Reporting Entity experienced quarterly patient care revenue losses during some, but not all, of the quarters during the period of availability of funds, may Provider Relief Fund payments be used to cover losses during those quarters only?

Supporting Data

What documentation is required for reporting?

What are the documentation retention requirements for the Provider Relief Fund?

Change of Ownership

Who is responsible for reporting use-of-funds in the event of a change of ownership after receipt of a Provider Relief Fund payment?

Non-Financial Data

Why is HRSA requiring Reporting Entities to report patient metrics?

What if a Reporting Entity does not believe their patient encounters align with one of the patient visit type options?

Should dialysis chairs be counted as staffed beds if a patient is admitted as an inpatient?

What are the categories for patient metrics?

What are the categories for classifying personnel?

What is considered a “staffed bed” for reporting facility metrics?

Extensions

What if a Reporting Entity missed the reporting deadline and subsequently returned funds, as requested by HRSA, but would now like to receive the funds and report on the use of funds due to extenuating circumstances?

Will HRSA allow late report submissions?

Are providers able to request extensions on submissions of their required reports for any of the required reporting periods?

Are providers able to request extensions on the deadline to use funds?

Miscellaneous

If an entity received Provider Relief Fund and/or American Rescue Plan (ARP) Rural payment(s) totaling over $10,000, but returned some, do they still have to report?

If a Reporting Entity plans to report on General Distribution payments that were transferred from a subsidiary that received the initial payment, how should patient care revenue or lost revenues be aggregated and reported in the portal?

If a Reporting Entity returned funds and the returned funds are not reflected in the “Payments to Recipients” page in the PRF Reporting Portal, what should the Reporting Entity do?

If a Reporting Entity returns unused funds in excess of the amount owed, will HRSA repay the Entity the difference between what was owed and returned?