As promised, the PRF reporting portal is now open as of July 1, 2021, for submitting reports on the stimulus payments received. HHS outlined four separate payment reporting periods as outlined below. A provider only has to report if it received in excess of $10,000 in a single payment period in the table below. Hopefully by now, someone from your organization has registered an account in the portal.
The reporting portal is accessible at this address: PRF Reporting Portal. The reporting portal is only compatible with the most recent version of Microsoft Edge, Google Chrome, and Mozilla Firefox.
Provider Relief Fund Reporting Periods
For purposes of reporting on payments received, the provider will need to verify the date that the payment was received to determine which reporting period the payment should be accounted for. The payment received date is considered to be the deposit date for automated clearing house (ACH) payments or the check cashed date.
Provider Relief Fund recipients must only use payments for eligible expenses, including services rendered and lost revenues attributable to coronavirus before the deadline that corresponds to the Payment Received Period, which is based on the date the payment is received. Providers are required to maintain supporting documentation which demonstrates that costs were obligated/incurred during the period of availability, as required under the Terms and Conditions. However, Reporting Entities are not required to submit that documentation when reporting.
For purchases of tangible items made using PRF payments, the purchase does not need to be in the provider’s possession (i.e., back ordered PPE, ambulance, etc.) to be considered an eligible expense, but the costs must be incurred before the Deadline to Use Funds. Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.
Recipients may use payments for eligible expenses or lost revenues incurred prior to receipt of those payments (i.e., pre-award costs) so long as they are to prevent, prepare for, and respond to coronavirus. However, HHS expects that it would be highly unusual for providers to have incurred eligible expenses or lost revenues prior to January 1, 2020.
It is critically important for providers to capture all eligible expenses and lost revenue. According to the FAQs, the provider must return any unused funds to the government within 30 calendar days after the end of the applicable Period of Reporting.
On June 11, 2021, HHS issued updated FAQs and guidelines in anticipation of the July 1 reporting portal. However, at that time, there were some significant unanswered questions, mainly around the issue of calculating lost revenue. In these guidelines and FAQs issued on July 1, they have clarified the calculation of lost revenue.
What is the maximum allotment of my organization’s Provider Relief Fund amount that can be allocated to lost revenues during the period of availability of funds? (Modified 7/1/2021)
There is not a maximum or minimum that can be allocated. Reporting Entities will see the reporting system asks for unreimbursed expenses attributable to coronavirus first in the overall use of funds calculation; it is possible for a Reporting Entity to enter “0”. Provider Relief Fund payment amounts not fully expended on unreimbursed health care-related expenses attributable to coronavirus during the period of availability are then applied to lost revenues. Lost revenues or expenses must only have been incurred during the period of availability correlating to the Payment Received Date as described in the June 11 Post-Payment Notice of Reporting Requirements.
For Option i and Option ii, lost revenues are calculated for each quarter during the period of availability, as a standalone calculation, with 2019 quarters serving as a baseline.
For each calendar year of reporting, the applicable quarters where lost revenues are demonstrated are totaled to determine an annual lost revenues amount. There is no offset. Option iii provides maximum flexibility to providers by allowing providers to calculate lost revenues using an alternate reasonable methodology.
Can recipients use 2020 budgeted revenues as a basis for reporting lost revenues? (Modified 7/1/2021)
Yes. When reporting use of Provider Relief Fund payments toward lost revenues attributable to coronavirus, Reporting Entities may use budgeted revenues if the budget(s) and associated documents covering calendar year 2020 were established and approved prior to March 27, 2020. To be considered an approved budget, the budget must have been ratified, certified, or adopted by the Reporting Entity’s financial executive, executive officer or other responsible representative as of that date, and the Reporting Entity will be required to attest that the budget was established and approved prior to March 27, 2020. Documents related to the budget, including the approval, must be maintained in accordance with the Terms and Conditions.
If a Reporting Entity has more lost revenue for a “Payment Received Period” than it received Provider Relief Fund payments for the same period, can that lost revenue be carried forward and applied against payments received during later “Payment Received Periods” and included in the lost revenues reported during later reporting periods? (Added 7/1/2021/)
Yes. Provider Relief Fund payments may be applied to expenses and lost revenues according to the period of availability of funding. However, expenses and lost revenues may not be duplicated. Specifically, payments received may not be applied to the same expenses and lost revenues that Provider Relief Fund payments received in prior payment periods already reimbursed. The Payment Received Periods described in the June 11, 2021 Post-Payment Notice of Reporting Requirements determine the period of availability of funding and when reports are due.
If a Reporting Entity experienced quarterly patient care revenue losses during some, but not all, of the quarters during the period of availability of funds, may Provider Relief Fund payments be used to cover losses during those quarters only? (Added 7/1/2021/)
Yes, lost revenues are calculated for each quarter during the period of availability, as a standalone calculation. Provider Relief Fund payments may be used to cover those quarters where patient care revenue losses occurred as long as those losses were attributable to coronavirus.
How will a Reporting Entity know if HRSA determines if its revenue estimation approach is considered reasonable? (Added 7/1/2021)
HRSA will notify a Reporting Entity if their proposed methodology is not reasonable, including if it does not demonstrate with a reasonable certainty that claimed lost revenues were caused by coronavirus. If HRSA determines that a Reporting Entity’s proposed alternate methodology is not reasonable, the entity will be asked to resubmit its report within 30 days of notification using either Option i or Option ii to calculate lost revenues attributable to coronavirus.
For purposes of reporting, it is all based on the mandated reporting periods without regard to a provider’s fiscal year.
HHS has made it very clear that there are no extensions.
Are providers able to request extensions on the deadline to use funds? (Added 7/1/2021)
No. HRSA will not approve extensions on the use of funds for any providers. Any unused funds must be returned to the government following the relevant Reporting Time Period.
Are providers able to request extensions on submissions of their required reports for any of the required reporting periods? (Added 7/1/2021)
No. Providers that received one or more payments exceeding $10,000, in the aggregate, during a Payment Received Period are required to report in each applicable Reporting Time Period. Providers that are required to report and do not submit a completed report by the applicable deadlines will be deemed out of compliance with the program Terms and Conditions and may be subject to recoupment.
Reporting Entities are not required to submit that documentation when reporting. Providers are required to maintain supporting documentation which demonstrates that costs were obligated/incurred during the period of availability. The burden of proof is on the Reporting Entity to ensure that adequate documentation is maintained.
Providers should already be maintaining documentation for eligible expenses. However, they may need to tweak the calculations for lost revenue to comply with the latest guidance from HHS.
HRSA has provided a PRF Reporting Portal – Data Entry Workbook at this site. Data Entry Workbook
HRSA will be hosting a webinar on Thursday, July 8, 2021 at 3:00 pm ET, on the reporting requirements. You can register for this webinar at HRSA Webinar for PRF Reporting. HRSA has indicated that the webinar will be recorded.
Following are some additional useful links.
PRF Post-Payment Reporting Requirements One Page Overview PRF Reporting One Page Overview
PRF Reporting Portal Home Page PRF Reporting Portal. There are additional links at this site for portal FAQs and reporting user guide.
PRF Frequently Asked Questions PRF FAQs
Post-Payment Notice of Reporting Requirements (June 11, 2021) Reporting Requirements June 11, 2021
For any questions related to the CARES Act Provider Relief Fund, or healthcare reimbursement in general, contact Dave Macke, VonLehman’s Director of Reimbursement Services, at dmacke@vlcpa.com or 800.887.0437.
