On June 13, 2020, the Department of Health and Human Services updated its guidance related to reporting requirements, temporarily extending the initial report that would have been due July 10.

As a bit of background, the most recent guidance for recipients of $150,000 or more from the Provider Relief Fund previously required that a detailed report be submitted no more than 10 days after the end of each calendar quarter. Based on this requirement, the first report after the end of quarter two (June 30) would have been due by July 10.

As of June 13, FAQs put out by the HHS here were updated to remove the language stipulating a deadline for filing. The updated guidance reads as follows (emphasis added):

Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision.

While it remains unclear what the exact reporting requirements will be, or whether any quarterly report will eventually be required, the current guidance clearly eliminates the report that was expected to be due by July 10. The FAQs make it clear that additional guidance remains forthcoming, and it is expected that all recipients of Provider Relief Fund payments will have to provide certain detailed support indicating how the payments have been used.

We will continue to monitor this situation for additional guidance and send further updates as information comes available. Until then, the best course of action will be to continue maintaining highly detailed records so that whatever level of detail is required, you will have the appropriate documentation to substantiate your usage.