HHS Provider Relief Fund Reporting Period 2 Is Open

Healthcare providers who received one or more Provider Relief Fund (PRF) payments exceeding $10,000, in aggregate, from July 1, 2020 to December 31, 2020, must report on how these funds were used by March 31, 2022 in the PRF Reporting Portal. Payment received during this period must have been used by December 31, 2021.

Reporting and auditing requirements are available through the Health Resources & Services Administration.

• For some providers, the portal will auto-populate previously entered data in certain fields. For those required to report in Period 1, the portal will calculate remaining unused lost revenues that can be reimbursed during future payment periods.
• For Reporting Period 2, providers will need to show how payments were applied to expenses and lost revenues for the Period of Availability, which is from Q1 2020 through Q4 of 2021, not to duplicate expenses applied in Reporting Period 1 for Q1 through Q2 2021.
• Returning Reporting Entities may change the methodology for calculating lost revenues, but must then use the new methodology to calculate lost revenues for the entire Period of Availability.

Click a question to skip to the answers you need:

• What are the PRF reporting requirements?
• What information do I need to complete the registration in the PRF Reporting Portal?
• Am I required to report both Eligible Expenses and Lost Revenue?
• What are the reporting requirements for Eligible Expenses?
• What are the reporting requirements for Lost Revenue?
• What happens if required reporting is not submitted by the deadline?

What are the PRF reporting requirements?

If you received $10,000 or more in aggregate, you or the reporting entity must report to maintain compliance within the respective reporting time. The data necessary includes:

• Interest earned on PRF payments
• Other assistance received, including Paycheck Protection Program Loans (PPP)
• Use of SNF and Nursing Home Infection Control (NHIC) payments (if applicable)
• Use of general and other targeted distribution payments
  • Eligible expenses must be attributable to coronavirus and not reimbursed by other assistance received.
• Net unreimbursed expenses attributable to coronavirus
  • Any eligible expenses not covered by other aid received and PRF payments applied are reported in this section.
• Lost revenues reimbursement
• Personnel, patient, and facility metrics

What information do I need to complete the registration in the PRF Reporting Portal?

You’ll need the following items:

• Tax ID Number (TIN)
• Business name as it appears on the Form W-9
• Contact information
• Address
• TIN’s of subsidiaries
• Payment information (for any one of the PRF 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

Am I required to report both Eligible Expenses and Lost Revenue?

You may report either Eligible Expenses or Lost Revenue if you have fulfilled the spending requirement using either method. However, it is encouraged to report both Eligible Expenses and Lost Revenue if you received any subsequent PRF payments. Any unused lost revenues in Reporting Period 2 will carry forward to future payment periods reporting.

What are the reporting requirements for Eligible Expenses?

Reporting Entities that received between $10,001 and $499,999 in aggregated PRF payments during each Payment Received Period are required to report on PRF payments in two categories: (1) General and Administrative Expenses and (2) Healthcare-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 PRF payments in greater detail, according to the following sub-categories of expenses:

• General and Administrative Expenses Attributable to Coronavirus: mortgage/rent, insurance, personnel, fringe benefits, lease payments, utilities/operations, and other general and administrative expenses
• Healthcare-Related Expenses Attributable to Coronavirus: Supplies, Equipment, Information Technology (IT), Facilities, and other healthcare-related expenses

What are the reporting requirements for Lost Revenue?

PRF payment amounts (excluding Nursing Home Infection Control Distribution payments) may be applied to patient care lost revenues. Patient care means healthcare, services, and supports, as provided in a medical setting, at home/telehealth, or in the community. There are three different options to calculate Lost Revenue, and below is the information needed for each option. You will be asked to provide a breakdown of the payer mix (Medicare A/B, Medicare C, Medicaid, commercial insurance, self-pay, and other) in Option i and Option ii.

• Option i: the difference between actual patient care revenues
  • Actuals for each quarter during the period of availability (2020 & 2021)
  • Actuals for 2019
• Option ii: the difference between budgeted and actual patient care revenues
  • Actuals for each quarter during Period of Availability
  • Budgets for each quarter during the Period of Availability
  • Copy of the budget approved before March 27, 2020
  • Executive-level attestation
• Option iii: any reasonable method of estimating revenues
  • Calculated lost revenues for each quarter during the Period of Availability
  • A narrative document describing the methodology, including an explanation of why the methodology is reasonable for the circumstances, and a description establishing how lost revenues were attributable to coronavirus (as opposed to a loss caused by any other source)
  • A calculation of lost revenues attributable to coronavirus using the methodology described in the narrative document

What happens if required reporting is not submitted by the deadline?

You are out of compliance and must return your PRF payments to the HRSA. In addition, non-compliant providers will be excluded from receiving and/or retaining future PRF payments—including any applicable Phase 4 payments.

Many providers continue to feel the impact of lost revenue, and Aldrich can help you maximize relief opportunities to get your practice back on track. HHS PRF recipients should review the updated reporting requirements and be prepared to submit the information in accordance with the appropriate deadline.

For more resources or help navigating the reporting process, contact your Aldrich Advisor.