Authored by Mark Ross and Alicia Caldwell
The Department of Health and Human Services (HHS) released “Post-Payment Notice of Reporting Requirements” (the Requirements) for both Provider Relief Fund (PRF) General and Targeted Distributions to healthcare providers. The Requirements include detailed information on provider reporting guidelines on the usage of PRF distributions, including the data elements that healthcare providers will be required to report. The Requirements supplement an earlier document, which outlined the timing of required reporting to HHS, and has indicated that the reporting system will now be available in early 2021.
The Requirements do not apply to the Nursing Home Infection Control or Rural Health Clinic testing distributions, nor does it apply to payments from the Health Resources and Services Administration (HRSA) Uninsured Program. Additional reporting guidance for these payments will be released in the future.
Baker Tilly noted that the Requirements specifically address the usage of PRF General and Targeted Distributions. The information outlined in the Requirements relative to the usage of the funds is significantly different than what was communicated by HHS in earlier guidance. The most notable differences and clarifications relate to the following:
- PRF General and Targeted Distributions not fully expended on healthcare related expenses attributable to coronavirus can be applied to lost revenues, as defined (i.e., the distributions need to be applied to expenses first, then to lost revenues); previous HHS guidance was silent relative the order in which the distributions needed to be applied.
- Lost revenues are now defined as a negative change in year-over-year net patient care operating income (i.e., patient care revenue less patient care related expenses), net of healthcare related expenses attributable to coronavirus (that are required to be applied to the distributions first). The year-over-year analysis will be based upon a calendar year comparison of 2019 and 2020; previous HHS guidance was silent relative to the consideration of patient care related expenses in the calculation of lost revenues.
- The determination of healthcare related expenses attributable to coronavirus and the calculation of lost revenues must consider the total amount of coronavirus-related relief received from other funding sources (e.g., Treasury, Small Business Administration, and the CARES Act/Paycheck Protection Program).
- Recipients may apply PRF General and Targeted Distributions toward lost revenues, as defined, up to the amount of their 2019 net gain from healthcare related sources. Recipients that reported negative net operating income from patient care in 2019 may apply PRF General and Targeted Distributions to lost revenues up to a net zero gain/loss in 2020.
- Recipients with unused funds as of Dec. 31, 2020 will have an additional six months to use remaining funds.
Baker Tilly will also continue to provide you with new information and HHS FAQs relative to the Requirements as they become available.
For more information about this topic, or to learn how Baker Tilly’s Value Architects™ can help, contact our team.