Provider Relief Fund: HHS Reporting Period Three
By Eric Sierant, Senior, Advisory Services
The Provider Relief Fund portal for U.S. Department of Health and Human Services (HHS) reporting period three is open until September 30, 2022. Providers who received one or more payments totaling more than $10,000 from January 1, 2021 to June 30, 2021 are required to submit a report on how the phase three funds were used. The funds were available to use from January 1, 2020 through June 30, 2022.
Providers logging into the portal for the first time need to register an account. Please note that it takes some time for registration to be approved. Providers who previously submitted an HHS report one and/or two do not need to register again.
Providers must submit the required report within the above timeframe to avoid having to return all funds that were not reported. Providers with remaining unused funds, or those who fail to submit the required report, must return funds to HHS within 30 calendar days after the phase three reporting deadline of September 30, 2022.
Similar to phases one and two, when reporting phase three spending, providers must determine if an expense is eligible for reimbursement through the Provider Relief Fund. According to the Health Resources & Services Administration, an expense is allowable if it is used to prevent, prepare for, and respond to the coronavirus. Provider relief funds, except infection control payments, may also be used for lost revenue attributable to the coronavirus. Recipients are responsible for maintaining adequate documentation showing these funds were used for healthcare-related expenses or lost revenue pertaining to the coronavirus. Reporting entities are not required to submit this documentation when initially reporting but should have it readily available.
Please see below for a few examples of allowable expenses that can be reported for phase three, per the HRSA website:
- Healthcare supplies and equipment.
- Telehealth software/hardware, including updated EMR modules to support patient care.
- Facility enhancements for improved infection control.
- Fringe benefits – recruitment and retention, hiring bonuses, health insurance, OT pay, etc.
- Direct employee expenses – nurses, supporting staff, contractor payroll administrator, etc.
- Mortgage/rent for clinical setting, medical office building, etc.
- Property, malpractice, or other business insurance.
Alternatively, providers can account for lost revenues in the reporting process. They do not need to account for a specific expense to “use” funding by the deadline; instead, they need to be able to document that the loss occurred during the relevant time period.
For reference, please see the provider relief fund lost revenues guide for reporting period two. (A guide for reporting period three has not yet been released by HRSA, but the process should be similar).
Providers submitting an HHS report for the first time should be aware that the report requires information about eligible expenses from the first quarter of 2020 through the second quarter of 2022, which is the time period the funds were eligible to be used. Providers reporting lost revenue must include quarterly amounts from 2019, 2020, 2021 and through the second quarter of 2022 – all broken down by payer source. Providers who previously completed the first and/or second reports will only need to update the new columns added.