Funds received by providers through the PRF can create anxiety for providers when ensuring funds are being properly used and reported. The Department of Health and Human Services (HHS) has clarified the rules regarding nonfederal entities that received money through the Provider Relief Fund, and single audits. The FAQ now has information about when funds should be used and when they should be reported based on when providers received funding. There are also more clearly defined deadlines on when unused funds should be returned if they cannot be spent or applied to losses during the correct time period.
New Guidance on Reporting
New answers have been added to the department's FAQ section about the PRF, including how PRF funds can be used and what must happen with unused funds, and when reporting is due based on when payments were received. PRF funds can only be used on payments for eligible expenses which include services rendered and lost revenue during the applicable period.
The department has issued rolling deadlines for when funds must be used and reported. For instance, funds that were received between 4/10/2020 and 6/30/2020 had to be used by 6/30/2021. Reporting on those funds could be completed between 7/1/2021 and 9/30/2021.
The update includes a table outlining the schedule for when funds must be both used and reported. The periods are:
● 4/10/2020 to 6/30/2020. These funds must be used by 6/30/2021 and reported between 7/1/2021 and 9/30/2021.
● 7/1/2020 to 12/31/2020. These funds must be used by 12/31/2021 and reported between 1/1/2022 and 3/31/2022.
● 1/1/2021 to 6/30/2021. These funds must be used by 6/30/2022 and reported between 7/1/2022 and 9/30/2022.
● 6/1/2021 to 12/31/2021. These funds must be used by 12/31/2022 and reported between 1/1/2023 and 3/31/2023.
Nonfederal entities like for profit providers will include PRF expenditures in their schedule of expenditures for federal awards (SEFA) for fiscal years that end on or after June 30, 2021. This means that if your organization had a fiscal year that ended between December 31, 2020 and June 29, 2021, your PRF expenditures would not be included in your SEFA.
The Governmental Audit Quality Center (GAQC) has confirmed that new guidance supersedes previous instructions. GAQC is still working to determine both the relevance and impact of the guidance provided to for-profit entities who receive PRF funding. They'll continue to update as new developments occur.