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Legal Insights and Perspectives for the Healthcare Industry

The US Department of Health and Human Services (HHS) announced on Friday, January 15, 2021, one month before the former reporting deadline, that it will push back the CARES Act Provider Relief Fund (PRF) reporting timeline due to the enactment of the Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (the Act). HHS has been working to provide updated reporting requirements that comply with this recently passed legislation.

Consequently, PRF recipients will now be required to submit their reporting requirements on their use of these funds later than previously announced. (“In the near future, HRSA will announce the window for submitting the first report on a recipient’s use of funds.”) See PRF Frequently Asked Questions (modified 1/15/21). Starting on January 15, 2021, however, PRF recipients may begin registering for gateway access to the PRF Reporting Portal where they will ultimately submit their information in compliance with the new reporting requirements HHS is issuing.

A new General and Targeted Distribution Post-Payment Notice of Reporting Requirements was also released by HHS on January 15, 2021 in accordance with the Act. This document supersedes the November 2, 2020 notice and does not apply to recipients of funds from the Nursing Home Infection Control distributions; the Rural Health Clinic Testing distribution; the Health Resources and Services Administration (HRSA) COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program; and the HRSA COVID-19 Vaccine Administration Assistance Fund. Additional reporting may be announced in the future for these reimbursements, according to HHS.