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HHS Announces Provider Relief Fund Reporting Update

1/18/21 – Dave Macke

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On Friday, January 15, 2021, the U. S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced that it is amending the reporting timeline for the Provider Relief Fund Program (PRF) due to recent passage of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA).  HHS has been working to provide updated reporting requirements to comply with the legislation that was passed by Congress last month and signed by the President on December 27, 2020.  Consequently, the original reporting deadline of February 15, 2021, is being delayed. 

Starting January 15, 2021, providers may begin registering for gateway access to the Reporting Portal where they will ultimately submit information in compliance with the new reporting requirements. 

Provider Relief Fund Reporting Requirements

The PRF Reporting Requirements were updated on January 15, 2021, and this document supersedes the November 2, 2020 posting.  Some of the information stays the same.  The report is still to be used to submit your coronavirus related expenses and lost revenues to HHS.  As previously stated, the allowable expenses are those expenses that are reasonable and necessary and used to prevent, prepare for and / or respond to the coronavirus.  Additionally, expenses can only be claimed if not obligated or reimbursed by another source.

Expenses are to be reported in two categories.

  1. General & Administrative Expenses
  2. Healthcare Related Expenses

For those providers between $10,000 and $499,999, providers will only need to report total expenses at the category level.  For those providers $500,000 and above, providers will have to report expenses by individual subcategories, under these two categories.  This is consistent with the prior guidance.

However, the definition of lost revenue has changed significantly.      

Recipients may choose to apply PRF payments toward lost revenue using one of the following options, up to the amount:

a) of the difference between 2019 and 2020 actual patient care revenue;

b) of the difference between 2020 budgeted and 2020 actual patient care revenue. If recipients elect to use 2020 budgeted patient care revenue to calculate lost revenue, they must use a budget that was established and approved prior to March 27, 2020. Providers using 2020 budgeted patient care revenue to calculate the amount of lost revenues they may permissibly claim will be required to submit additional documentation at the time of reporting; or

c) calculated by any reasonable method of estimating revenue. If a recipient wishes to use an alternate reasonable methodology for calculating lost revenues attributable to coronavirus, the recipient must submit a description of the methodology, an explanation of why the methodology is reasonable, and establish how the identified lost revenues were in fact a loss attributable to coronavirus, as opposed to a loss caused by any other source. All recipients seeking to use an alternate methodology face an increased likelihood of an audit by HRSA. HRSA will notify a recipient if their proposed methodology is not reasonable, including a scenario where the recipient does not establish with reasonable certainty that claimed lost revenues were caused by coronavirus. If HRSA determines that a recipient’s proposed alternate methodology is not reasonable, the recipient must resubmit its report within 30 days of notification using either 2019 calendar year actual revenue or 2020 calendar year budgeted revenue to calculate lost revenues attributable to coronavirus.

If recipients do not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to coronavirus but not reimbursed by other sources, and/or lost revenues in an amount not to exceed the difference between: 1) 2019 Quarter 1 to Quarter 2 and 2021 Quarter 1 to Quarter 2 actual revenue, or 2) 2020 Quarter 1 to Quarter 2 budgeted revenue and 2021 Quarter 1 to Quarter 2 actual revenue.

Note: Reporting Entities with unused funds after December 31, 2020, must submit a second and final report no later than July 31, 2021, that includes patient care related revenue amounts earned January 1–June 30, 2021.

2020 Facility, Staffing and Patient Care (per quarter)

a. Personnel Metrics: Total personnel by labor category (e.g., full-time, part-time, contract, other: recipient must define), total rehires, total new hires, and total personnel separations by labor category.

b. Patient Metrics: Total number of patient visits (in-person or telehealth), total number of patients admitted, and total number of resident patients.

c. Facility Metrics: Total available staffed beds for medical/surgical, critical care, and other beds.

The complete document issued by HHS can be found here.

Registration Now Open

Recipients of PRF payments exceeding $10,000 in aggregate must register in the Provider Relief Fund Reporting Portal. At present, there is no deadline for completing registration in the portal. Recipients will later receive a notification about when they should complete the second step of submitting reporting requirements information on the use of funds. HRSA will send a broadcast email to the email address you provide during the registration process.

The registration process will take at least 20 minutes to complete and must be completed in one session. You cannot save a partially complete registration. Make sure you have all of the information required to register before you begin. Here is the link to the reporting portal to register. The portal is only compatible with the most current version of Edge, Chrome, and Mozilla Firefox.

Information that will be needed to register in the portal

  • Tax ID Number (TIN) (or other number submitted during the application process (e.g., Social Security Number, Employer Identification Number (EIN))
  • Business name (as it appears on a W-9) of the reporting entity
  • Contact information (name, phone number, email) of the person responsible for submitting the report
  • Address (street, city, state, five digit zip code) of the reporting entity as it appears on a W-9)
  • TIN(s) of subsidiaries (if a provider is reporting on behalf of subsidiary(ies) - in a list delimited by commas, e.g.,123456789,987654321,135791357)
  • Payment information (for any of the payments received)
    • TIN of entity that received the payment 
    • Payment amount 
    • Mode of payment (check or direct deposit ACH) 
    • Check number or ACH settlement date 

You will also need to create a username (in the form of an email) and a password during the registration process.

Additional Resources

HRS has provided additional resources to assist providers in this process. Both of these documents contain some helpful information.

Provider Relief Fund (PRF) Reporting Portal FAQs

Provider Relief Fund Reporting Portal User Guide

VonLehman will continue to provide assistance to providers in this reporting.

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.