The COVID-19 pandemic presented unprecedented challenges to healthcare providers. In response, the U.S. government introduced the Cares Act Healthcare Relief Program, offering financial assistance through initiatives like the Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural payments. For recipients of these critical funds, understanding the guidelines for eligible expenses and revenue losses is paramount. This guide clarifies the crucial periods of availability for these funds and outlines key compliance requirements.
Understanding PRF and ARP Rural Payment Usage
Recipients of PRF and ARP Rural payments are entrusted with these funds to cover specific expenses and offset lost revenues directly attributable to the COVID-19 pandemic. It’s essential to recognize that these funds come with designated periods for eligible use. These periods are determined by when the payment was received, ensuring the funds are applied to costs incurred during the height of the pandemic and its immediate aftermath.
The key is to utilize these funds for expenses incurred within the “Period of Availability.” This period varies depending on when the payment was received. Crucially, while funds can be used for lost revenues, this eligibility is capped at June 30, 2023, coinciding with the end of the quarter in which the COVID-19 Public Health Emergency concluded.
To simplify understanding, refer to the table below which clearly outlines the payment received periods and the corresponding periods of availability for both eligible expenses and lost revenues:
| Period | Payment Received Period | Period of Availability for Eligible Expenses | Period of Availability for Lost Revenues |
|---|---|---|---|
| 1 | April 10, 2020, to June 30, 2020 | January 1, 2020, to June 30, 2021 | January 1, 2020, to June 30, 2021 |
| 2 | July 1, 2020, to December 31, 2020 | January 1, 2020, to December 31, 2021 | January 1, 2020, to December 31, 2021 |
| 3 | January 1, 2021, to June 30, 2021 | January 1, 2020, to June 30, 2022 | January 1, 2020, to June 30, 2022 |
| 4 | July 1, 2021, to December 31, 2021 | January 1, 2020, to December 31, 2022 | January 1, 2020, to December 31, 2022 |
| 5 | January 1, 2022, to June 30, 2022 | January 1, 2020, to June 30, 2023 | January 1, 2020, to June 30, 2023 |
| 6 | July 1, 2022, to December 31, 2022 | January 1, 2020, to December 31, 2023 | January 1, 2020, to June 30, 2023 |
| 7 | January 1, 2023, to June 30, 2023 | January 1, 2020, to June 30, 2024 | January 1, 2020, to June 30, 2023 |
Understanding the Period of Availability for Cares Act Healthcare Relief Funds is crucial for compliance.
Defining Eligible Expenses and Lost Revenues
PRF and ARP Rural funds are intended to cover a broad range of costs incurred in preventing, preparing for, and responding to the coronavirus public health emergency. Eligible expenses include services rendered within the period of availability. Recipients can also utilize these funds to compensate for lost revenues attributable to COVID-19, but, as mentioned, this is limited to revenue losses incurred up to June 30, 2023 for most payment periods, except for Period 7.
Examples of eligible expenses are varied and can include:
- Services received: This covers a wide spectrum of healthcare services delivered during the specified period.
- Completed renovations or constructions: Facility upgrades or expansions completed within the period to enhance healthcare delivery capabilities.
- Tangible property ordered: Even if delivery was delayed, tangible items like medical equipment or ambulances ordered within the period qualify as eligible expenses, as long as the cost was incurred within the Period of Availability.
It’s important to note that for larger projects encompassing both services and tangible goods (like capital projects), reimbursement is contingent on the project’s full completion within the Period of Availability associated with the Payment Received Period.
Recipients have flexibility in applying these funds to eligible expenses or lost revenues incurred even before receiving the payments, dating back to January 1, 2020, as long as these costs were related to COVID-19 preparedness and response. While pre-award costs are permissible, the Department of Health and Human Services (HHS) anticipates that expenses or lost revenues incurred before January 1, 2020, would be uncommon.
Documentation, Audits, and Compliance
Maintaining meticulous records is not just good practice; it’s a strict requirement. Providers must retain comprehensive documentation demonstrating that costs were indeed incurred during the Period of Availability. While this documentation isn’t routinely submitted with reports, it must be readily available upon request from HHS for potential audits.
HHS retains the right to audit recipients both presently and in the future. Failure to adequately document fund usage or utilizing funds inconsistently with program requirements may lead to recoupment of funds. Every recipient, by attesting to the Terms and Conditions of the program, has committed to maintaining this necessary documentation to substantiate the appropriate use of these vital healthcare relief funds.
By adhering to these guidelines and carefully tracking fund allocation and expenses, healthcare providers can ensure they remain compliant with the Cares Act Healthcare Relief Program and continue to provide essential services to their communities.
