HFMA Comments on CARES Act Provider Relief Fund (PRF) Compliance Questions

In a December 4, 2020, letter to HHS, HFMA noted that while its members greatly appreciate the additional detail provided in the October 28th update to the FAQs and the November 2 revisions to the PRF reporting instructions it is concerned that the current reporting requirements continue to conflict with the prior FAQs issued by HHS and do not provide sufficient detail to PRF recipients so that they can ensure they are reporting their expenses and lost revenue attributed to the coronavirus accurately. Furthermore, the requirements deviate from the initial intent of supporting American families, workers and the heroic healthcare providers in the battle against the COVID-19 outbreak. In the letter, HFMA provides key questions identified by a task force of HFMA members consisting of accountants who provide audit services to healthcare providers, attorneys, and healthcare finance consultants, related to the November 2 reporting requirements that must be clarified. Given the technical nature of these questions, in addition to identifying them, the task force has also developed suggested clarifications based on their understanding of the CARES Act, Financial Accounting Standards Board (FASB) /Governmental Accounting Standards Board (GASB) accounting standards, the myriad of laws and regulations that govern the healthcare industry and common provider practice.

Download the comment letter