On June 11, 2021, the Department of Health and Human Services (HHS) released revised reporting requirements for healthcare providers who received Provider Relief Fund (PRF) payments.

The new requirements expand the length of time providers will have to report information, reduce burdens on smaller providers, and extend key deadlines for expending provider relief fund payments for recipients who received payments after June 30, 2020.

• The period of availability of funds is based on the date the payment is received (rather than requiring all payments to 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 90 days 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

According to HHS Post-Payment Notice of Reporting Requirements, recipients will report data in the following order:

1. Interest earned on PRF payment(s)
2. Other assistance received, including Paycheck Protection Program (PPP) Loans, Federal Emergency Management Agency (FEMA) program, HHS CARES Act Testing, other government assistance, and insurance reimbursement
3. Use of nursing home infection control distribution payments (if applicable)
4. Use of general and other targeted distribution payments: expense categories will include general and administrative and/or other healthcare-related expenses by the current year quarter
5. Net unreimbursed expenses attributable to COVID-19
6. Lost revenues reimbursement: PRF payment amounts not fully expended on healthcare-related expenses attributable to COVID-19 may then be applied to patient care lost revenues, using one of the following options:
   1. Option i: up to the amount of the difference between 2019 and 2020 actual patient care revenues.
   2. Option ii: up to the amount of the difference between 2020 budgeted (established and approved prior to March 27, 2020) and 2020 actual patient care revenues. A copy of a budget and an attestation from the reporting entity’s Chief Executive Officer or similar responsible individual is required.
   3. Option iii: calculated by any reasonable method of estimating revenues. The recipient must submit a description of the methodology, explain why it is reasonable, and establish how the identified lost revenues were a loss attributable to COVID-19. All recipients seeking to use an alternate methodology face an increased likelihood of an audit by HRSA.
   4. Reporting requirement: reporting entities will submit revenues/net charges from patient care by payer mix listed below, and by quarter for each quarter during the period of availability. Reporting entities electing Option i will provide actuals, and Reporting Entities electing Option ii will provide both budgeted and actuals. Payer mix includes Medicare Part A or B, Medicare Part C (Medicare Advantage), Medicaid/Children’s Health Insurance Program (CHIP), commercial insurance, self-pay (no insurance), or other.

• Parent entities can report on behalf of their subsidiaries with respect to any General Distribution funds received by the parent or subsidiaries. However, the original recipient of any Targeted Distributions must report with respect to the use of the Targeted Distribution funds. This is required regardless of whether the parent or subsidiary received the Targeted Distribution payment, or whether the original recipient subsequently transferred the payment.
• Reporting entities are expected to report on their use of PRF using their normal basis of accounting (e.g., cash or accrual) and to submit consolidated reports.
• Supporting worksheets will be available to assist Reporting Entities with the 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 burden of proof is on the reporting entity to ensure that they maintain adequate documentation that the funds were used for healthcare-related expenses or lost revenues attributable to COVID-19, and that those expenses or losses were not reimbursed from (or obligated to be reimbursed by) other sources.
• Reporting Entities that received $500,000 or more in aggregated PRF payments are required to report healthcare-related expenses attributable to COVID-19, 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 COVID-19: mortgage/rent, insurance, personnel, fringe benefits: lease payments, utilities/operations, and other expenses
  • The actual healthcare-related expenses attributable to COVID-19: supplies, equipment, information technology (IT), facilities, other healthcare-related expenses
• Reporting entities must indicate if they are subject to Single Audit requirements during 2019 through current fiscal years, and if yes, whether PRF payments are included in the Single Audit.
• For-profit organizations that expend $750,000 or more in annual awards have two options under 45 CFR 75.216(d) and 75.501(i): 1) a financial-related audit of the award or awards conducted in accordance with Generally Accepted Government Auditing Standards; or 2) an audit in conformance with the requirements of 45 CFR 75.514 (Single Audit). Provider Relief Fund General and Targeted Distribution payments (93.498) and Uninsured Testing, Treatment, and Vaccine Administration reimbursement payments (93.461) must be included in determining whether an audit in accordance with 45 CFR Subpart F is required (i.e., total annual awards expended are $750,000 or more).
• If a recipient does not have sufficient COVID-19 attributable expenses or losses to support the funds received, the funds must be returned to HHS. HHS indicates that recipients will be able to return unused funds through the Reporting Portal when the first reporting period begins on July 1, 2021.

The HHS Provider Relief Fund recipients should review the updated reporting requirements and be prepared to submit the information in accordance with the appropriate deadline. We will continue to monitor updates related to Provider Relief Fund reporting guidance and timelines and provide additional updates as released.

For more resources, contact your Aldrich Advisor.

This article was written with the most up-to-date information available as of June 30, 2021. Please check back for future updates.