On Oct. 22, 2020, the Department of Health and Human Services (HHS) released a "Reporting Requirements Policy Update" (the Update) related to both Provider Relief Fund (PRF) General and Targeted Distributions to healthcare providers. The Update includes new information related to the “Post-Payment Notice of Reporting Requirements” that was published on Sept. 19, 2020.
The Update indicates that the Sept. 19, 2020 reporting instructions limited the applicability of funds to an amount that would allow most providers to be no more profitable in 2020 than in 2019. At the time, HHS concluded that it would be inequitable to allow some providers to be more profitable in 2020 than 2019, while so many other providers struggled to remain viable. This decision to prohibit most providers from using PRF payments to become more profitable than they were pre-pandemic has generated significant attention and opposition from many stakeholders and members of Congress. There is consensus among stakeholders and members of Congress that HHS should allow a provider to apply PRF payments against all lost revenues without limitation.
This has resulted in HHS amending its reporting instructions to provide for the full applicability of PRF distributions to lost revenues. Here is the link to the updated "Post-Payment Notice of Reporting Requirements."
Baker Tilly will continue to provide you with new information and HHS FAQs relative to these matters as they become available.
For more information about this topic, or to learn how Baker Tilly’s Value Architects™ can help, contact our team.