HHS Provider Relief Fund Reporting Deadline Postponed

The U.S. Department of Health and Human Services (HHS) announced last week that it will be amending the reporting timeline for the Provider Relief Fund Program (PRF) due to the recent passage of the new stimulus package. With the new stimulus package, which added another $3 billion in funding to the PRF program, HHS is updating the PRF reporting requirements to be consistent with this new law. The deadline to submit the report has also been postponed.

While there is currently no deadline for providers to establish a reporting account in the newly enabled Reporting Portal, all providers will be required to complete registration to advance and fulfill their reporting requirements once HHS announces the new deadline to do so. Recipients of PRF payments exceeding $10,000 in aggregate must register in the Provider Relief Fund Reporting Portal. Once registered, recipients will later receive a notification about when they should complete the second step.

You will need all of the following information to complete registration:

• 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)
• 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

Recipients will report their use of PRF payments using their normal method of accounting (cash or accrual basis) by submitting the following information:

• Healthcare-related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse, including General and Administrative (G&A) and/or other healthcare-related expenses.
• PRF payment amounts not fully expended on healthcare-related expenses attributable to coronavirus are then applied to patient care lost revenues, using one of the following options, up to the amount:
  • of the difference between 2019 and 2020 actual patient care revenue;
  • of the difference between 2020 budgeted and 2020 actual patient care revenue. The budget needs to be established and approved before March 27, 2020.
  • calculated by any reasonable method of estimating revenue. The recipient must submit a description of the methodology, explain why the methodology is reasonable, and establish how the identified lost revenues were a loss attributable to coronavirus. All recipients seeking to use an alternate methodology face an increased likelihood of an audit by HRSA.
• Calendar year actual revenues will be entered by quarter and by payer mix: Medicare Part A or B, Medicare Part C, Medicaid/Children’s Health Insurance Program (CHIP), commercial insurance, self-pay (no insurance), and others.
• Reporting Entities with unused funds after December 31, 2020 will have an additional six months to use remaining amounts toward expenses attributable to coronavirus but not reimbursed by other sources and/or lost revenues. The entity 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.
• Reporting Entities that received $500,000 or more in aggregated PRF payments are required to report healthcare-related expenses attributable to coronavirus, net of other reimbursed sources, in greater detail than the two categories of G&A expenses and other healthcare-related expenses, according to the following subcategories of expenses:
  • General and Administrative Expenses Attributable to Coronavirus: mortgage/rent, insurance, personnel, fringe benefits: lease payments, utilities/operations, and other costs not captured above.
  • The actual healthcare-related expenses attributable to coronavirus: supplies, equipment, information technology (IT), facilities, other Healthcare Related Expenses not previously captured above.

For Reporting Entities that held the PRF payment(s) reported on in an interest-bearing account, the dollar value of interest earned on those PRF payments must be reported. The total reportable use of PRF distributions will be inclusive of the interest earned on those PRF distributions.

• Other assistance received includes any funding from the Treasury, Small Business Administration (SBA) and Paycheck Protection Program (PPP) Assistance, Federal Emergency Management Agency (FEMA) Assistance, CARES Act Testing, Local, State, and Tribal Government Assistance, and business insurance.
• Transfer of Target Distribution received by a subsidiary to another by the parent organization is permitted. The subsidiary that is the Reporting Entity must indicate the amount of any of the Targeted Distributions it received that were transferred to the parent entity. Transferred Targeted Distributions face an increased likelihood of an audit by HRSA.

2020 Facility, Staffing and Patient Care (per quarter)

• Personnel Metrics: Total personnel by labor category (e.g., full-time, part-time, contract, other: the recipient must define), total rehires, total new hires, and total personnel separations by labor category.
• Patient Metrics: Total number of patient visits (in-person or telehealth), total number of patients admitted, and total number of resident patients.
• Facility Metrics: Total available staffed beds for medical/surgical, critical care, and other beds.

Change in Ownership

Reporting Entities that acquired or divested of related subsidiaries during the calendar year 2020 indicate the change in ownership, whether the related TIN was acquired or divested, providing the following data points for each relevant TIN:

• Date of acquisition/divestiture
• TIN(s) included in the acquisition/divestiture
• Percent of ownership for acquisition/divestiture
• Did/do you hold a controlling interest in this entity?

Reporting Entities that expended $750,000 or more in aggregated federal financial assistance during their fiscal year (including PRF payments and other federal financial assistance) are subject to Single Audit requirements, as set forth in the regulations at 45 CFR 75.501.

The HHS Provider Relief Fund recipients should begin reviewing reporting requirements and be prepared to submit the information when the reporting account is opened in the portal. We are monitoring the updates on the reporting requirements and will continue to provide guidance on the next steps. For more resources, please visit our COVD-19 Resource Center.

This article was written with the most up-to-date information available as of January 19, 2021. Please check back for future updates.