HHS- Provider Relief Funds (PRF) Update
On Friday, June 11th the Heath Resources & Services Administration released a revised notice of reporting requirements and reporting timeline for recipients of the provider relief fund payments. The full notice can be found at the below link.
There are still a lot of unanswered questions, but we wanted to provide you a quick summary on what additional information was released and what your current action items should be.
- The deadline of using your HHS funds is based on the date the payment was received. Below is a chart showing the various dates based on when funds were received. There was no additional guidance given on the use of the funds. We believe that additional information will be released as we get closer to the July 1st launch of the PRF portal. Please reference our HHS blog that was done on October 23rd, 2020 (https://www.fluenceportland.com/consulting/hhs-grant-relief-fund-phase-3) for additional information on expense and tracking.
- The Reporting Portal will be open on July 1, 2021. The reporting period is based on when the payment was received. The below chart will provide the various reporting time periods. Please note that recipients will have a 90-day period to completed reporting. This was extended from the original 30-day reporting period.
- You will be required to report each payment received separately. The deadline to use the funds, as well as the reporting period, is done separately for each payment received.
- You cannot report early; you must wait until your reporting period begins.
- If you received $10,000 or less in total during a “payment received period,” you do not need to report anything for that period.
Use of Funds & Reporting Time Period Chart
|Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)||Deadline to Use Funds||Reporting
|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, 2022||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|
- If you have not done so already, you must register in the PRF Reporting Portal. This must be done in advance of the Reporting period. Please reference our HHS blog that was done on February 12th (https://www.fluenceportland.com/budgeting/hhs-provider-relief-fund-registration-is-open-and-you-must-register). This will provide the link to register and the information you will need to complete the registration.
- Understand what is approved use of the funds. We have covered this in the October 23rd, 2020, and the February 12th, 2021, blogs which are referenced above. No additional information has been released since our last blog. We recommend that you use the Excel spreadsheet provided in the blogs for Covid expense tracking. Please remember the deadline for the use of the funds has changed from the dates previously referenced in our blogs; use the above chart to determine your period.
- As we found out with the PPP reporting process, we believe reporting rules may change and become more simplified as the reporting process develops. For this reason, we believe there is no need to be an early reporter; you have 90 days once your reporting period begins. Mark your calendar and set a reminder to begin reporting closer to the end of your reporting window.
Our commitment to you
- We believe that additional information will be released as the reporting portal opens and others report. We will continue to stay on top of updates and will release blogs to help you through this process. At this point in time, no additional information has been released regarding the approved ways to use the Provider Relief Funds. Please reference the above February 12th blog for the ways the grant can be used.
- PPP1/Employee Retention Credit (ERC) – If you have not submitted your PPP 1 loan forgiveness application to your bank, we recommend that you start this process now. If you have asked Fluence to help you, we are working our way through these calculations to help optimize your ERC tax credit and will be reaching out to you when these calculations are completed.
- If you have not asked Fluence to help with your forgiveness application or ERC tax credit, but you would like some help, please reach out to your manager, and we will add you to our list.
- PPP2- we recommend that you wait until your 24- week covered period is up before you apply for loan forgiveness. Most banks are not accepting PPP2 forgiveness applications yet and probably will not until September. We think it is important to allow both the bank and SBA to make it through PPP1 applications first before submitting for PPP2 forgiveness. Since you have 10 months after your 24-week covered period is up, there no rush.