PRB Reporting and Auditing FAQ
Download all Provider Relief Fund FAQs (PDF - 376 KB)
Use of Funds
Yes, Health Center Program COVID-19 Grants awarded to FQHCs and FQHC Look-Alikes for costs for expenses or losses that were potentially eligible for payments under the Provider Relief Fund and/or ARP Rural Distribution would need to be fully drawn down before Provider Relief Fund or ARP Rural payments could be used during the applicable period of availability. The Provider Relief Fund and ARP Rural Distribution required that payments not be used to reimburse expenses or lost revenues that have been reimbursed from other sources or that other sources are obligated to reimburse. If FQHCs or FQHC Look-alikes have incurred expenses or lost revenues attributable to coronavirus that these grant awards do not cover, they may use Provider Relief Fund or ARP Rural payments towards those expenses or losses. Grant funding may be awarded to support either broad or specific allowable uses, depending on the terms and conditions of the award. Recipients must use grant funding awarded by HRSA for the purposes (as budgeted) approved by HRSA. Should those costs also be eligible for payment under the Provider Relief Fund or ARP Rural Distribution, a Health Center Program-funded health center or look-alike must use their grant funds before utilizing Provider Relief Fund or ARP Rural payments.
(Updated 10/27/2022)
To be considered an allowable expense under the Provider Relief Fund or ARP Rural Distribution, the expense must be used to prevent, prepare for, and respond to coronavirus. Provider Relief Fund and ARP Rural payments may also be used for lost revenues attributable to the coronavirus up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ends. Reporting Entities are required to maintain adequate documentation to substantiate that these funds were used for health care-related expenses or lost revenues attributable to coronavirus or COVID-19, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them.
Reporting Entities were not required to submit that documentation when reporting. Providers were required to maintain supporting documentation which demonstrated that costs were incurred during the Period of Availability. The Reporting Entity was responsible for ensuring that adequate documentation was maintained.
(Modified 5/5/2023)
Expenses for capital facilities could have been fully expensed only in cases where the purchase was directly related to preventing, preparing for and responding to the coronavirus. Examples of these types of facilities projects include:
- Upgrading a heating, ventilation, and air conditioning (HVAC) system to support negative pressure units
- Retrofitting a COVID-19 unit
- Enhancing or reconfiguring ICU capabilities
- Leasing or purchasing a temporary structure to screen and/or treat patients
- Leasing a permanent facility to increase hospital or nursing home capacity
In order for the capital facilities projects’ costs to have been expensed, the project must have been fully completed by the end of the Period of Availability associated with the Payment Received Period.
(Updated 8/30/2021)
Health care-related operating expenses were limited to costs incurred to prevent, prepare for, and respond to coronavirus. The amount of mortgage or rent eligible for Provider Relief Fund or ARP Rural reimbursement was limited to that which was incurred to prevent, prepare for, and respond to coronavirus or COVID-19. Providers are required to maintain documents to substantiate that these funds were used for health care-related expenses attributable to coronavirus, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them. The burden of proof is on the provider to ensure that documentation is maintained to show that expenses are to prevent, prepare for, and respond to coronavirus.
(Updated 10/27/2022)
Provider Relief Fund and ARP Rural payments may have been applied to expenses or lost revenues attributable to coronavirus, after netting the other funds received or obligated to be received which offset those expenses. If a provider submitted an application to FEMA, but had not yet received the FEMA funds, the provider should not have reported the requested FEMA amounts in the Provider Relief Fund and/or ARP Rural report. If FEMA funds were received during the same Payment Received Period in which provider reported on use of Provider Relief Fund and/or ARP Rural payments, the receipt and application of each payment type is required in the Provider Relief Fund and/or ARP Rural reporting process. If an entity received a retroactive payment from FEMA that overlapped with the period of availability, the entity must not use the FEMA payment on expenses or lost revenues already reimbursed by Provider Relief Fund or ARP Rural payments.
(Updated 10/27/2022)
No. For purchases of tangible items made using Provider Relief Fund and/or ARP Rural payments, the purchase does not need to be in the Reporting Entity’s possession (i.e., backordered personal protective equipment, capital equipment) to be considered an eligible expense. However, the costs must have been incurred before the Deadline to Use Funds. Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.
(Updated 10/27/2022)
Yes, providers that already had a cost allocation methodology in place at the time they received funds, may allocate normal and reasonable overhead costs to their subsidiaries, which may be an eligible expense if attributable to coronavirus or COVID-19 and not reimbursed from other sources.
(Updated 10/27/2022)
Expenses attributable to coronavirus may include items such as supplies, equipment, information technology, facilities, personnel, and other health care-related costs/expenses for the period of availability. The classification of items into categories should align with how Provider Relief Fund and/or ARP Rural payment recipients maintain their records. Providers can identify their expenses attributable to coronavirus, and then offset any amounts received through other sources, such as direct patient billing, commercial insurance, Medicare/Medicaid/Children’s Health Insurance Program (CHIP); other funds received from the federal government, including the Federal Emergency Management Agency (FEMA); the Provider Relief Fund COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured (Uninsured Program); the COVID-19 Coverage Assistance Fund (CAF); and the Small Business Administration (SBA) and Department of the Treasury’s Paycheck Protection Program (PPP). Provider Relief Fund and/or ARP Rural payments may be applied to the remaining expenses or costs, after netting the other funds received or obligated to be received which offset those expenses. The Provider Relief Fund and ARP Rural Distribution permitted reimbursement of expenses related to coronavirus provided those expenses have not been reimbursed from other sources or that other sources are not obligated to reimburse.
(Updated 10/27/2022)
Recipient must follow CMS instructions for completion of cost reports.
Under cost-based reimbursement, the payer agreed to reimburse the provider for the costs incurred in providing services to the insured population. If the full cost were reimbursed based upon this method, there is nothing eligible to report as a Provider Relief Fund or ARP Rural expense attributable to coronavirus because the expense was fully reimbursed by another source. Provider Relief Fund and/or ARP Rural payments cannot be used to cover costs that were reimbursed from other sources or that other sources are obligated to reimburse. Therefore, if Medicare or Medicaid made a payment to a provider based on the provider’s Medicare or Medicaid cost, such payment generally was considered to fully reimburse the provider for the costs associated with providing care to Medicare or Medicaid patients and no payment from the Provider Relief Fund or ARP Rural Distribution would be available for those identified Medicare and Medicaid costs. Per its authorizing statutes, Provider Relief Fund resources may only be used for allowable expenses and lost revenues attributable to coronavirus, and may only be reimbursed once. Reporting Entities should work with their accountants and maintain documentation demonstrating that any reported health care expenses that Provider Relief Fund and/or ARP Rural payments were applied to were not reimbursed by any other source, or obligated to be reimbursed by another source.
However, in cases where a ceiling is applied to the cost reimbursement, or the costs were not reimbursed under cost-based reimbursement (such as costs for care to commercial payer patients), and the reimbursed amount by Medicare or Medicaid does not fully cover the actual cost, those non-reimbursed costs were eligible for reimbursement under the Provider Relief Fund or ARP Rural Distribution.
(Updated 10/27/2022)
Time spent by staff on COVID-19-specific matters may be an allowable cost attributable to coronavirus so long as it was not reimbursed or obligated to be reimbursed by other sources. If the personnel salaries were reimbursed by any other source of funding they cannot be also reimbursed by the Provider Relief Fund or ARP Rural Distribution. In addition, no one individual may be allocated as greater than one full-time equivalent (FTE) across all sources of funding. All costs must have been tangible expenses (not opportunity costs) and supported by documentation.
The Reporting Entity must maintain appropriate records and cost documentation including, as applicable, documentation described in 45 CFR §75.302 – Financial management and 45 CFR §75.361 through §75.365 – Record Retention and Access, and other information required by future program instructions to substantiate the reimbursement of costs under this award. The Recipient must promptly submit copies of such records and cost documentation upon the request of the Secretary, and the Reporting Entity agrees to fully cooperate in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with these Terms and Conditions.
(Updated 10/27/2022)
Yes. Providers may not use Provider Relief Fund or ARP Rural payments to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse. Therefore, if a hospital has received Medicaid DSH payments for the uncompensated costs of furnishing inpatient and/or outpatient hospital services to Medicaid beneficiaries and to individuals with no source of third-party coverage for the services, these expenses would be considered reimbursed by the Medicaid program and would not be eligible to be covered by money received from a General or Targeted Distribution or ARP Rural payment. Read more about the calculation of the Medicaid hospital-specific DSH limit - PDF (PDF).
(Updated 10/27/2022)
Yes, if funds were held in an interest-bearing account, they would be considered reportable revenue. If interest was earned on Provider Relief Fund disbursements that the Reporting Entity expended in full, the interest amounts may be retained and applied toward a reportable use of funds.
If interest is earned on funds that are only partially expended, the interest on remaining unused funds must be calculated, reported, and returned.
Recipients of ARP Rural and PRF Phase 4 payments are required to hold those payments in an interest-bearing account per the Terms and Conditions. Reporting Entities must report on the dollar value of interest earned on all retained ARP Rural payments, separately from Provider Relief Fund Distributions. The total reportable amount of ARP Rural and Provider Relief Fund payments will include the interest earned.
(Modified 10/27/2022)
No. As it relates to expenses, providers identify their health care-related expenses, and then apply any amounts received through other sources (e.g., direct patient billing, commercial insurance, Medicare/Medicaid/CHIP, reimbursement from the Provider Relief Fund COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured, or funds received from FEMA or SBA/Department of Treasury’s Paycheck Protection Program) that offset the health care-related expenses. Provider Relief Fund payments may be applied to the remaining expenses or cost, after netting the other funds received or obligated to be received which offset those expenses.
(Added 12/28/2020
Yes, expenses incurred by providers to secure and maintain adequate personnel, such as offering hiring bonuses and retention payments, child care, transportation, and temporary housing, were deemed to be COVID-19-related expenses if the activity generating the expense was newly incurred after the declaration of the Public Health Emergency and the expenses were necessary to secure and maintain adequate personnel.
(Modified 10/27/2022)
Yes, outsourced or third-party vendor services that enable sustained access to health care services and daily operations, such as food/patient nutrition services, facilities management, laundering, and disinfection/anti-contamination services, were considered reimbursable expenses if they are attributable to coronavirus.
(Updated 10/27/2022)
Yes. HHS considers taxes imposed on Provider Relief Fund or ARP Rural payments to be “healthcare related expenses attributable to coronavirus” that are reimbursable with Provider Relief Fund or ARP Rural money, except for Nursing Home Infection Control Distribution payments.
(Updated 10/27/2022)
As it relates to expenses, providers identify their health care-related expenses, and then apply any amounts received through other sources (e.g., direct patient billing, commercial insurance, Medicare/Medicaid, reimbursement from the Provider Relief Fund COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured, or funds received from FEMA or SBA/Department of Treasury’s Paycheck Protection Program) that offset the health care-related expenses. Provider Relief Fund and/or ARP Rural payments may be applied to the remaining expenses or cost, after netting the other funds received or obligated to be received which offset those expenses.
(Modified 10/27/2022)
Providers who used accrual or cash basis accounting may report the relevant depreciation amount based on the equipment useful life, purchase price and depreciation methodology otherwise applied.
For additional information on capital depreciation, please refer to the other Frequently Asked Questions related to capital equipment and capital facility projects.
(Updated 12/11/2020)
Expenses for capital equipment and inventory could be fully expensed only in cases where the purchase was directly related to prevent, prepare for and respond to the coronavirus. Examples of these types of equipment and inventory expenses include:
- Ventilators, computerized tomography scanners, and other intensive care unit- (ICU) related equipment put into immediate use or held in inventory
- Masks, face shields, gloves, gowns
- Biohazard suits
- General personal protective equipment
- Disinfectant supplies
(Updated 10/27/2022)
Direct employee (full and part-time), contract labor, and temporary worker expenses are eligible expenses provided they are not reimbursed from other sources, or only the incremental unreimbursed amounts are claimed.
The Terms and Conditions associated with Provider Relief Fund and ARP Rural payment do not permit recipients to use Provider Relief Fund and/or ARP Rural payments to pay any salaries at a rate in excess of Executive Level II which is currently set at $197,300 (2020), $199,300 (2021), $203,700 (2022), $212,100 (2023). For the purposes of the salary limitation, the direct salary is exclusive of fringe benefits and indirect costs. The limitation only applies to the rate of pay charged to Provider Relief Fund and/or ARP Rural payments and other HHS awards. An organization receiving Provider Relief Fund and/or ARP Rural payments may pay an individual’s salary amount in excess of the salary cap with non-federal funds.
An example of how this Executive Level II Salary cap is applied to aggregated personnel expenses is shown below. Reimbursement from other sources is applied in Step Two. Providers should apply reasonable assumptions when estimating the portion of personnel costs that are reimbursed from other sources.
Step One
| Personnel Category | Number of Personnel | Personnel Expenses | Personnel Expenses (Below Salary Cap) | Ineligible for Federal Reimbursement |
|---|---|---|---|---|
| Medical Director | 1 | $250,000 | $197,300 | $52,700 |
| Registered Nurse | 25 | $1,250,000 | $1,250,000 | 0 |
| Security | 2 | $80,000 | $80,000 | 0 |
| 28 | $1,580,000 | $1,527,300 | $52,700 |
Step Two
| Personnel Expenses (Below Salary Cap) | Less FEMA Reimbursement | Less Reimbursement from Other Sources | Eligible Personnel Expenses |
|---|---|---|---|
| $1, 527,300 | ($50,000) | ($1,000,000) | $477,300 |
(Modified 10/27/2022)
Yes, fringe benefits associated with both types of personnel may have been eligible if not reimbursed by other sources.
(Updated 10/27/2022)
HHS initially advised providers that once a subsidiary TIN attested to and accepted a General Distribution payment, the money must stay with, and be used by, the subsidiary TIN. However, HHS has received feedback indicating that some subsidiary TINs accepted a General Distribution payment prior to the release of this guidance, and that they would have had their parent TIN accept the money, had they known earlier of HHS’s position. In light of these timing concerns, HHS is revising its prior guidance and clarifying that, for General Distribution payments only, a subsidiary TIN can transfer its General Distribution payment to a parent TIN; this is true even if a subsidiary TIN initially attested to accepting a General Distribution payment. Consistent with other longstanding guidance, the parent TIN may use the money and/or allocate the money to other subsidiary TINs, as it deems appropriate.
Regardless of which entity (the parent or subsidiary) attested to the receipt of the General Distribution payments, the parent entity can report on the use of the General Distribution payment as part of the HHS reporting process.
(Added 10/28/2020)
No. Provider Relief Fund payments and ARP Rural payments must be used for different expenses or lost revenues attributable to coronavirus or COVID-19. A provider may not use an ARP Rural payment to cover eligible health care expenses or lost revenues attributable to coronavirus or COVID-19 if the provider has already reported that their Provider Relief Fund payment(s) have covered the eligible expense or lost revenues. If a provider received both types of payments, the provider should have applied their ARP Rural payment towards eligible health care expenses and lost revenues attributable to COVID-19 before utilizing Provider Relief Fund payments to cover eligible health care expenses or lost revenues attributable to coronavirus. One way to ensure funds are not used for the same expenses or lost revenues attributable to coronavirus or COVID-19 may be to use them for different time periods.
(Updated 4/6/2022)
The opportunity to apply Provider Relief Fund payments (excluding the Nursing Home Infection Control Distribution) and ARP Rural payments for lost revenues will be available up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ends.
(Modified 5/5/2023)