HHS Issues Revised Post-Payment Notice of Reporting Requirements for Provider Relief Funds

On Friday, June 11, 2021, the U.S. Department of Health and Human Services (HHS) through the Health Resources and Services Administration (HRSA) issued revised reporting requirements for recipients of CARES Act Provider Relief Fund (PRF) payments.  The release also included updated reporting requirements and auditing issues as well as updated Frequently Asked Questions (FAQs).

In what is perhaps the most significant change, payments received are now separately identified and reported into one of four payment periods based on the date received.  The payment is considered received on the deposit date for automated clearing house (ACH) payments or the check cashed date.  A Provider will only report if they received more than $10,000 in a single period rather than the aggregate.  Funds received will be separately reported based on the applicable period received.  Any excess funds that a Provider cannot use by the deadline, based on the period the payment was received, will have to pay the excess back to HHS.  The process to pay back the excess funds has not yet been established by HHS.  Following are some key updates.

• The period of availability of funds is based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received).
• Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).
• Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period).
• The reporting requirements are now applicable to recipients of the Skilled Nursing Facility and Nursing Home Infection Control Distribution in addition to General and other Targeted Distributions.
• The PRF Reporting Portal will open for providers to start submitting information on July 1, 2021.

Period	Payment Received Period (Payments Exceeding $10,000 in Aggregate Received)	Deadline to Use Funds	Reporting Time Period
Period 1	April 10, 2020 to June 30, 2020	June 30, 2021	July 1, 2021 to September 30, 2021
Period 2	July 1, 2020 to December 31, 2020	December 31, 2021	January 1, 2022 to March 31, 2022
Period 3	January 1, 2021 to June 30, 2021	June 30, 2022	July 1, 2022 to September 30, 2022
Period 4	July 1, 2021 to December 31, 2021	December 31, 2022	January 1, 2023 to March 31, 2023

What documentation is required for reporting? (Modified 6/11/2021)

Supporting worksheets will be available to assist Reporting Entities with completion of reports. In addition, Reporting Entities who are using a portion of their funds for lost revenues may be required to upload supporting documentation when reporting on their calculation of lost revenues. The documentation required is dependent upon which method of calculating lost revenues providers select. Please review the most recently published Post-Payment Notice of Reporting Requirements for additional details.

What are the documentation retention requirements for the Provider Relief Fund? (Added 10/28/2020)

Providers need to retain original documentation for three years after the date of submission of the final expenditure report, in accordance with 2 CFR 200.333.

Reporting Entities that received between $10,001 and $499,999 in aggregated PRF payments during each Payment Received Period are required to report on the use of these infection control payments in two categories: (1) General and Administrative Expenses and (2) Health Care-Related Expenses.

Reporting Entities that received $500,000 or more in aggregated PRF payments during each Payment Received Period are required to report on the use of these infection control payments in greater detail than the two categories of General and Administrative Expenses and Health Care-Related Expenses, according to the following sub- categories of expenses:

General and Administrative Expenses Attributable to Coronavirus

1. Mortgage / Rent
2. Insurance
3. Personnel
4. Fringe Benefits
5. Lease Payments
6. Utilities / Operations
7. Other General and Administrative Expenses

Health Care-Related Expenses Attributable to Coronavirus

1. Supplies
2. Equipment
3. Information Technology (IT)
4. Facilities
5. Other Health Care-Related Expenses

Lost Revenue Reimbursement

PRF payment amounts (excluding Nursing Home Infection Control Distribution payments) not fully expended on health care-related expenses attributable to coronavirus may then be applied to patient care lost revenues, if applicable.  Documentation requirements for lost revenues calculations are further defined within the Data Elements section.  Recipients may choose to apply PRF payments toward lost revenues using one of three options, up to the amount:

1. Option i: of the difference between actual patient care revenues;
2. Option ii: of the difference between budgeted (prior to March 27, 2020) and actual patient care revenues.
3. Option iii: calculated by any reasonable method of estimating revenues.

Other Assistance Received

The Reporting Entity must enter other assistance received by quarter during the period of availability.  If the Reporting Entity is reporting on behalf of subsidiaries, the assistance received for each category must be aggregated across each of the subsidiaries included in the report.

1. Department of the Treasury and/or Small Business Administration (SBA) Assistance
2. Federal Emergency Management Agency (FEMA) Programs
3. HHS CARES Act Testing
4. Local, State, and Tribal Government Assistance
5. Business Insurance
6. Other Assistance

Personnel, Patient, and Facility Metrics

Reporting Entities will report on the following personnel, patient, and facility metrics by quarter for CY 2019 through the current period of availability.

a. Personnel Metrics: Total number of clinical and non-clinical personnel by labor category (full-time, part-time, contract, furloughed, separated, hired).

b. Patient Metrics: Total number of inpatient admissions, outpatient visits (in-person and virtual), emergency department visits, and facility stays (for long-term and short-term residential facilities).

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

Survey

Reporting entities will answer questions regarding the impact of payments during the period of availability in the following categories.

a. Overall operations

b. Maintenance of solvency and prevention of bankruptcy

c. Retention of staff and prevention of furlough

d. Re-hire or re-activation of staff from furlough

e. Facilitation of changes needed to operate during the pandemic

f.  Ability to care for and/or treat patients with COVID-19 (for applicable treatment facilities)

g. Impact on business or patient services (narrative statement) [optional]

What should providers do now?

1. Register in the PRF Reporting Portal to create an account so you are ready to report when your reporting period opens.  You will have three months to report.
2. Make sure that you have the appropriate documentation to support eligible expenses and lost revenue.  Note:  There are 3 options for lost revenue.
3. There are other data elements that providers must include in their report.  There are general questions on organizational structure, subsidiary relationships, interest earned on PRF Funds that were placed in an interest-bearing account, tax status, single audit status and other assistance received.
4. Patient care revenue (net patient revenue) must be reported by quarter beginning in calendar year 2019 and segregated by payor category.
5. Make sure you have the required Personnel, Patient, and Facility Metrics and Survey questions.

Following are links to documents that were released last Friday and the PRF Reporting Portal.,

HHS Press Release

Reporting Requirements and Auditing

Post-Payment Notice of Reporting Requirements

CARES Act Provider Relief Fund FAQs

Provider Relief Fund Reporting Portal

PRF Reporting Portal Frequently Asked Questions (FAQs)

PRF Reporting Portal – User Guide

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.