Late on July 30, 2020, the U.S. Department of Health and Human Services (HHS) published guidance establishing a July 31, 2021, deadline for providers to fully expend their Provider Relief Fund distributions. Just last week, HHS announced initial reporting requirements for recipients of general and targeted distributions that received one or more payments exceeding $10,000, including a July 31, 2021, final reporting deadline. However, as mentioned in our prior client update, the announcement left uncertainty as to the deadline to fully expend or return distributions.

As of now, if you received a payment from the General Distribution (including the $30 billion tranche, the $20 billion tranche, or Medicaid, Dental, & CHIP allocation) or a Targeted Distribution, you must fully expend or return any unused portion of your distribution by July 31, 2021. HHS has not yet issued instructions on how to return unused funds.