July 19, 2021

Fund Reporting Period

By Jesus Fung, Manager, Advisory Services

Fund Reporting Period Healthcare

As the economy is transitioning to a new normalcy, skilled nursing facilities are also slowly recovering from the impact of the pandemic on the industry. Although occupancy has not yet returned to pre-pandemic levels, occupancy has been steadily increasing over the past six months. Throughout, SNFs have made major efforts to maintain staffing levels, ensuring proper social distance protocols are enforced, and adequate supplies of personal protective equipment. Together with vaccination programs for residents and staff, these efforts have put providers in a better position to avoid significant outbreaks of COVID in their facilities, despite concerns about coronavirus variants in the U.S.

Upcoming Reporting Deadlines

The industry has absorbed the additional costs associated with these efforts while facing significant lost revenue. Programs such as the Provider Relief Fund (PRF) from U.S. Health and Human Services (HHS), local state funding, Paycheck Protection Program (PPP) Round 1 and 2 loans from the U.S. Small Business Administration, and other economic relief programs played a critical role in keeping the industry above water. For many providers, these funds were their only source of financial support. In the upcoming months, providers will be required to submit their report on the usage of the funds and ensure compliance under each program’s terms and conditions.

In the coming months, providers will be required to submit their reports on how these funds were utilized, demonstrating compliance under each program’s terms and conditions.

Provider Relief Fund

  • On June 18, 2021, HHS released the new timeline to use and report the funds received.
Summary of Reporting Requirements
  Payment Received Period
(Payments Exceeding $10,000 in Aggregate Received)
Deadline to Use Funds Reporting Time Period
Period 1 From April 10, 2020 to June 30, 2020 June 30, 2021 July 1 to September 30, 2021
Period 2 From July 1, 2020 to December 31, 2020 December 31, 2021 January 1 to March 31, 2022
Period 3 From January 1, 2021 to June 30, 2021 June 30, 2020 July 1 to September 30, 2022
Period 4 From July 1, 2021 to December 31, 2021 December 31, 2022 January 1 to March 31, 2023

Providers have one year to use the funds received during the periods illustrated in the table above. The reporting process has been split into four periods, each with its own deadline for the use of funds and also a specific reporting time period. We are currently in the first reporting window for which providers will need to report on the use of their HHS funds received between April 10, 2020 through June 30, 2020. The reporting portal recently opened and all providers should be in the process of gathering the required information.

They will also have an additional three months to report on how funds were used.  Rather than a single report covering all funds received, providers must separate eligible expenses and lost revenue in reporting funds received in each of the four periods. Many providers may have already spent funds received in 2020, so now is the time to begin planning and assembling information. Providers should not wait until the second reporting window from January 1 to March 31, 2022, to start the planning process. This can also be done for funds received in Period 3 (January 1, 2021 to June 30, 2021).

PPP Round 1 Forgiveness

  • As for the PPP Round 1 loans, the window to submit forgiveness applications is within the next couple of months for providers who received their loans and have completed the full 24-week covered period. Providers must submit their forgiveness applications prior to 10 months following their covered period end date. The lender has 60 days from receipt of a complete PPP loan forgiveness application to review, and then the SBA has up to 90 days to issue a decision. If a completed loan forgiveness application has not been submitted to the lender within the specified timeframe, the first payment will automatically become due to the lender. A completed application means that all required supporting documentation has been submitted along with the forgiveness application.

Now is the time to review and ensure that reporting deadlines are met for each of the funding programs. Providers need to make sure eligible expenses are not duplicated among their different reports. Categories such as payroll, rent/mortgage, utilities, and personal protective equipment are eligible expenses for most funding, but providers cannot report that the money received were used on the same expenses from each funding program. Providers will need to review that the reporting reflects the amount of fund received and the eligible expenses for each period.

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