The Department of Health and Human Services (HHS) issued the long-awaited Provider Relief Fund (PRF) Reporting Requirements Saturday, September 19, detailing the data elements that recipients will be required to submit as part of a post-payment reporting process.
In addition, the new guidance appears to modify previous positions taken by HHS regarding how providers may apply their PRF funds to healthcare-related expenses and lost revenues attributable by the COVID-19 pandemic.
All PRF recipients of greater than $10,000 in total payments must submit reports through a template and platform that is still forthcoming.
Important elements of the requirements and guidance are summarized below:
Healthcare related expenses attributable to COVID-19
Providers that received between $10,000 and $499,999 in aggregated PRF payments must report healthcare-related expenses attributable to COVID-19 and the net amount of other reimbursed sources in two general categories: general and administrative expenses and other healthcare-related expenses.
- Providers that received $500,000 or more in PRF payments must report more detailed information within these two general categories.
- Providers are advised that only those expenses over and above the amount reimbursable by other sources are to be reported within the two general categories noted. Providers will report the total amount of other assistance received (such as loans from the Paycheck Protection Program) within the ‘lost revenues’ section of reporting requirements.
Lost revenues attributable to COVID-19
In the case that PRF funds remain after being applied to healthcare expenses, the excess amount may be applied to ‘lost revenue’ which HHS now defines as “year-over-year net patient care operating income”. Previously, the HHS guidance permitted “any reasonable method of estimating lost revenue” such as comparing budgeted versus actual income.
In addition, the new guidance appears to place a cap on the amount of PRF funds applied towards lost revenue to the following amounts:
- the amount of a provider’s 2019 net gain from healthcare related sources
- up to a net zero gain/loss in 2020, if the provider reported negative net operating income in 2019.
Other Guidance – HHS includes further clarifications on reporting expectations including:
- A parent entity can report on the use of general distribution PRF payments by its subsidiaries, but each subsidiary entity that received a targeted distribution PRF payment must individually report on the use of its payments.
- Providers receiving more than $750,000 in federal awards, which include Provider Relief Funds, are subject to single audit requirements (under the code of federal regulations) as clarified by FAQs issued in July. These providers will need to identify that they fit that requirement and if their auditors selected the PRF funds to be within the scope of audit.
- If providers do not expend PRF in full by the end of calendar year 2020, they will have until June 30, 2021, to use the remaining amounts toward qualifying expenses and lost revenues. The January-June 2021 reporting period will be compared to January-June 2019, and lost revenues reported for 2021 may not exceed the provider’s 2019 net gain.
- The reporting requirements do not apply to the Nursing Home Infection Control distribution, the Rural Health Clinic Testing distribution, or reimbursement from the Health Resources and Services Administration (HRSA) Uninsured Program.
- October 1, 2020: Previously announced date for opening the reporting platform. HHS now has said this action will not take place until early 2021.
- February 15, 2021: Deadline by which to submit a first report due for PRF expenditures through December 31, 2020
- July 31, 2021: Deadline by which to submit a second and final report for January 1 – June 30, 2021 revenues and expenditures if applicable.
There is potential that these timelines may be altered in the case that the public health emergency (PHE) is extended beyond the current October 23rd, 2020 deadline or in the case that additional legislation is passed allocating more resources towards the PRF.
The entire post-payment notice of reporting requirements, which includes further details and examples of data included within reporting, is available HERE.
More information on the Provider Relief Fund is available HERE.
As always, ADVOCATE will continue to keep you informed on the issues impacting medical groups as they develop.
Manager, Regulatory Affairs