The long-awaited guidance on HHS Provider Relief Fund (PRF) reporting was issued through a post-payment notice of reporting requirements document located here. The document contains more than just information on reporting uses of PRFs; it provides guidance and clarification on eligible uses of funding. For many recipients, this release has gigantic implications!
Get help breaking down what the new reporting requirements mean for you.
Reporting Requirements and Data Elements of PRF Guidance
First and foremost, HHS is requiring all recipients of greater than $10,000 in aggregate PRF payments to submit reports through a tool that has not yet been released. The reporting deadlines and timelines are noted within the original Post-Payment Notice located here.
All entities are required to report their use of PRF payments by submitting certain data elements:
The reporting requirements and updated guidance does not apply to the Nursing Home Infection Control or Rural Health Clinic Testing distributions; it also does not apply to the HRSA Uninsured Program.
Major Impacts of Newly Released Provider Relief Fund Guidance
Through this release, HHS completely changed the way many entities calculated and viewed lost revenues. Lost revenues are now defined as “a negative change in year-over-year net patient care operating income (i.e. patient care revenue less patient care related expenses…), net of the healthcare related expenses attributable to coronavirus.”
There is also a cap on allowed lost revenues up to the amount of 2019 net gain from healthcare related sources, and if an organization had a net operating loss from patient care in 2019, the lost revenue cap is up to a breakeven for 2020. Calculations focusing solely on changes in revenue by month or department, etc., will now need to be reconsidered. If the funds are not fully used by December 31, 2020, lost revenues may be claimed through June 2021 by comparing the net operating income of the year-to-date 2021 results with the same period in 2019.
HHS defines both patient care revenues and expenses within this notice. A very important item for consideration is that revenues used to calculate net operating must include relief under the SBA Paycheck Protection Program (PPP); CARES Act testing funds; FEMA CARES Act funds; local, state and tribal government assistance, etc. While these items are defined in the notice, they do seem to create more questions and likely will require clarification.
The notice also further defines “expenses attributable to coronavirus.” Again, further clarification will likely be needed, but it does now include “lease or purchase of permanent or temporary structures, or to modify facilities to accommodate patient treatment practices revised due to coronavirus.” This clarifies previous guidance that only included temporary structures/facilities.
Finally, HHS has identified that all PRF funds must be expended by June 30, 2021, which is slightly earlier than the previous interpretation of July 2021.
Next Steps Your Healthcare Organization Can Take
This likely has significant impacts to all organizations and individuals receiving PRF funds. Review the notice and start identifying and tracking the required information. Entities will also need to determine how the data, likely on a general ledger basis, fits into the HHS reporting elements. While the reporting is on a calendar year basis, some information is on a quarterly basis, so data elements can be accumulated now to reduce the workload leading up to the deadline.
This also may significantly impact the amounts that are currently expected to be covered by the PRF program, often reducing what was expected. Since the lost revenue requirements are now on a calendar-year basis, this creates timing and estimate concerns organizations/individuals on June, September, or other alternate year-ends.
As shown by this release, clarifications will continue to have large impacts on this program. Since this is expected to have material impacts on many recipients, we encourage communication with congressional delegates and others to advocate concerns of the negative impacts to providers from this release.
The fact is understanding and complying with Provider Relief Fund guidance can be confusing.