HHS Releases Reporting Requirements for Provider Relief Funds

On September 19, 2020, Health and Human Services released long-awaited reporting requirements for recipients of federal Provider Relief Funds (PRF) in excess of $10,000. The following summary of current PRF reporting requirements does not apply to the Nursing Home Infection Control distribution or the Rural Health Clinic Testing distribution. They also do not apply to the Uninsured Program.

Recipients will report the use of their funds in two categories. The first allows the recipient to report any healthcare related expenses due to COVID-19 that were not reimbursed from another source. The second is for any PRFs received in excess of the healthcare related COVID-19 expenses. The entity may be allowed to attribute funds in the second category to lost revenue.

HHS has divided PRF recipients into two groups for the part of the reporting section entitled “Expenses Attributable to Coronavirus Not Reimbursed by Other Sources.” Those receiving between $10,000 and $499,999 will take a broader approach and report expenses in two categories: 1) general and administrative (G&A) expenses and 2) other healthcare related expenses. Recipients of $500,000 or more will be required to provide detailed information about their expenditures by subgroups. Subgroups for G&A include rent, insurance, personnel, fringe benefits, lease payments, utilities, and other G&A. Subgroups for other healthcare related expenditures include supplies, equipment, information technology, facilities, and other healthcare related expenses.

For PRFs in excess of qualifying expenditures, recipients should determine whether any of the PRF payments could offset lost revenues. Previous HHS FAQ’s indicated that this would be a very broad calculation, either through a budgetary or year over year revenue comparison. Under the updated reporting requirements, however, the new calculation is an operating income comparison. Recipients are allowed to use lost revenues from healthcare related sources up to their 2019 net gain, from healthcare related sources, or up to a net zero gain in 2020 if they had a loss in 2019.

These new stipulations may limit the recipient’s lost revenue. This new calculation not only looks at revenue but looks at expenses from 2019 to 2020 which, for a variety of reasons, may not have been comparable. Recipients were not likely to have been looking at expense fluctuations year over year when determining whether to return potential excess funds.

In the “Lost Revenues Attributable to Coronavirus” section of the reporting module, recipients provide the total patient revenue, by quarter, for both 2019 and 2020. The entity also must disclose other funding received from the following sources: 1) SBA and CARES Act/PPP; 2) FEMA CARES Act; 3) CARES Act testing; 4) local, state, and tribal government assistance; 4) business insurance; and 5) other assistance. Lastly, the recipient will summarize the calendar year expenses for 2019 and 2020, by quarter, segregated by G&A and healthcare related expenses. Once all information is submitted, the system will automatically calculate any lost revenue that PRFs can be used to offset.

The HHS reporting system also will require certain non-financial data. Demographic information will include the reporting entity, the tax identification number, the national provider identifier, the fiscal year end date, and the federal tax classification. Recipients will need to provide, by quarter, personnel metrics, patient metrics, and facility metrics. The personnel metrics may include labor by category, hires and rehires, and terminations. Patient metrics will require information such as number of patient visits, patients admitted, and resident patients.

If there was a change in ownership for the reporting entity, certain details around the acquisition or divestiture must be disclosed. Finally, the entity should disclose whether it is subject to a Single Audit and whether the auditors have selected PRF to be within the scope of the Single Audit.

The reporting system will become available to recipients in early 2021. Recipients that have expended all funds prior to December 31, 2020 may submit one report. If a recipient has expenditures subsequent to December 31, 2020, a second and final report will be required.

You can find complete information related to audits and reporting requirements for Provider Relief Funds by downloading the white paper below. For more information about reporting requirements and other aspects of the Provider Relief Fund, contact us. We are here to help.

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