Over the past year, the department of Health and Human Services (HHS) has distributed billions in relief aid to healthcare providers impacted by the COVID-19 pandemic via the Provider Relief Fund (PRF). Initially established under the CARES (Coronavirus Aid, Relief, and Economic Security) Act, recipients of PRF monies must comply with the program’s terms and conditions to retain their payments, which requires reporting on the use of funds to HHS. Guidance on reporting requirements has been modified numerous times since the start of the program, most recently with the passage of the Consolidated Appropriations Act of 2021 this past December.
Below is our summary of the recent updates related to Provider Relief Fund reporting requirements.
What is the Provider Relief Fund?
The Provider Relief Fund distributes financial aid to eligible providers for healthcare-related expenses or lost revenue due to COVID-19. The fund distributed monies in several tranches under a ‘general distribution’, one of which was distributed automatically and two other tranches that required providers to apply.
Funds distributed under the ‘general distribution’ first sought to provide approximately 2% of annual revenue from patient care to a provider.
Who is required to report on Provider Relief Funds?
Any provider or groups who received PRF payments exceeding $10,000 in aggregate between any of the distributions, except for Nursing Home Infection Control distributions or the Rural Health Clinic Testing distributions.
What are the reporting requirements?
HHS has released updated reporting guidance on January 15th, 2021, which supersedes the latest guidance issued in November. The latest reporting requirements are available HERE.
Recipients must report their use of PRF payments using their normal method of accounting (cash or accrual basis) by providing the following information:
- Healthcare related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse.
- Recipients of PRF funds below $500,000 can net their expenses together and report how much was spent in two categories: general/administrative expenses and other healthcare expenses related to coronavirus. Recipients of funds above $500,000 must report the same categories, but in greater detail.
- PRF payment amounts not fully expended on healthcare related expenses attributable to coronavirus are then applied to patient care lost revenues.
When applying PRF amounts towards lost revenue, recipients can choose between the following when determining the amount:
- The difference between 2019 and 2020 actual patient care revenue;
- The difference between 2020 budgeted and 2020 actual patient care revenue. If using this method, the budget must be established and approved before March 27, 2020;
- Or calculated by “any reasonable method of estimating revenue”. Recipients opting for this option must submit details on the method used, explain why it is reasonable, and how the lost revenues identified were attributed to coronavirus. HHS states that recipients using an alternative method of calculation have an increased chance of being audited.
How do I report?
Reporting of Provider Relief Funds is done via a portal administered by the Health Resources and Services Administration (HRSA), a branch of HHS, which is available HERE.
At this time, PRF recipients can only register to use the portal – the operability of the portal for reporting purposes has been delayed, with no new date provided yet.
Registration, which takes approximately 20 minutes, must be completed before a user can begin reporting. Users will be notified when they can re-enter the portal to report on the use of funds.
Currently, there is no deadline to register for the portal. HRSA has released the following resources on the reporting portal:
If a recipient has not expended their PRF monies in full by the end of 2020, they will be required to submit one report for funds used in 2020 and a second report for the remaining funds used in 2021. Please note that the portal requires separate registrations for each TIN which received PRF funds.
What is the deadline to report?
The initial deadline for 2020 PRF reporting was set at February 15, 2021. However, HHS removed this date upon announcing that the reporting portal was open for registration on January 15th, 2021. HHS has not provided a new deadline at this time.
Where can I find more information on the PRF?
- HHS Provider Relief Fund – General Information for Providers
- HHS Provider Relief Fund – Reporting and Auditing
- HHS Provider Relief Fund – Frequently Asked Questions
As always, ADVOCATE will continue to keep you informed on the issues impacting medical groups as they develop.
Manager, Regulatory Affairs