In a follow-up to our recent HHS Reporting Requirements Client Alert on Thursday, July 1, 2021, the Department of Health and Human Services (HHS) and the Health Resources and Services Administration (HRSA) opened the Provider Relief Fund Reporting portal. HHS & HRSA have provided an Excel reporting workbook, a detailed user guide, and additional FAQs on the reporting portal for Provider Relief Funds. While this guidance has resolved some questions and has adapted prior guidance released, it has also left several key calculations and focus areas unresolved.
The Mueller Prost HHS Estimator Tool took a conservative approach on the eligibility and recognition of HHS funds, based on the interpretation of any updated FAQs. In light of these new FAQs and the post-reporting requirements document, the reporting requirements have altered which will require close attention to detail and advanced preparation.
Highlights of Changes:
Basics of Portal Navigation and Repayment
- When navigating in the portal providers will need to complete the data entry in a step-by-step process. Users will not be able to pick and choose what areas of the portal can be completed first.
- Logging into the portal requires a two-step authentication to ensure the correct reporting entity is logging into an account. When logging in each time, you will need to watch your email/spam for the verification code.
- Reporting entities must return any unspent funds to the government within 30 calendar days after the end of the applicable reporting period.
Coronavirus Expenses and Lost Revenue
- Coronavirus-related expenses must be reported by the calendar quarter. Reporting entities will be able to enter “0” for coronavirus-related expenses which would enable them to move on to reporting lost revenue (see page 36-42 of portal guide).
NOTE: There is a lack of specificity on the exact method for calculating COVID-related expenses that are “not reimbursed” and on the historical reference period for the calculation of lost revenue. The topic of eligible expense claims and the “payer of last resort” principle is a hotly debated topic among health care providers, accounting firms, and health care associations.
HHS continues to state that the “burden of proof” is on the Reporting Entity to maintain adequate documentation to substantiate that these funds were used for healthcare-related expenses or lost revenues attributable to coronavirus and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them.
As the burden of proof lies with the reporting entity and the guidance is unclear, we HIGHLY recommend that you are capturing all expenses that can be clearly delineated, identified, and which are coded as “COVID” related expense. Please refer to the complementary reporting notebook below to assist in capturing these expenses.
- The outcome from expense inputs will drive the following reporting screens relative to lost revenue calculations and claims.
- If a reporting entity reports coronavirus-related expenses that equal the other provider relief funds received, the reporting entity will report total 2019 and 2020 actual calendar year patient care revenue. This calendar year’s reporting of patient care revenue will not be used for lost revenue computations.
- If the reporting entity reports expenses that are less than other provider relief funds received, patient care revenue will be entered by quarter for the reporting period and this will be the basis for lost revenue computations. It is now clear that lost revenue in one quarter is not offset by increases in revenue in another quarter.
- If providers have a combination of coronavirus-related expenses and lost revenue in excess of provider relief funds received, we encourage providers to evaluate the degree of certainty associated with coronavirus-related expenses based on varying interpretations of the guidance and report those expenses with the highest degree of certainty.
- Nursing home infection control expenses will be reported separately from all other expenses related to coronavirus. The nursing home infection control expenses will be used to compute the amount of unspent funds associated to nursing home infection control that need to be repaid, if any. Lost revenue cannot be applied to nursing home infection control distributions received. Please note that most Nursing home infection control and quality incentive payments were received after June 30, 2020, and will be subject to Period 2 reporting requirements.
Information for Related Party Reporting Entities
- Any chains that are reporting multiple TIN’s, should be able to register using the same user name and password but need to do so for each TIN.
- The subsidiary questionnaire is an important step as the page contains conditional questions that affect how the reporting entity proceeds through the remainder of the reporting portal. We encourage providers to review the user guide and FAQs for additional instructions regarding these questions. The four questions in this section include:
- Does the reporting entity have any subsidiaries that are eligible health care providers?
- Did the reporting entity acquire or divest subsidiaries that are eligible health care providers and that received provider relief fund payments during the period of availability of funds?
- If the reporting entity is a subsidiary, will a parent entity report on any of the reporting entity’s General Distribution payment(s)
- Were any Targeted Distribution payment(s) transferred to/by a parent entity?
- If the user answers “yes” to either of the first two questions, the reporting entity will be taken to Step 3 in the portal.
- If the user answers “no” to both questions the reporting entity will be taken to Step 4 in the portal.
WHAT WE RECOMMEND AS AN ACTION STEP:
We highly recommend that you start to gather the data and documentation early to meet the reporting deadlines.
Key Next Steps
The following are some key takeaways we encourage provides to consider:
- Review all guidance issued by HHS and HRSA: HHS Reporting Resources
- Register for the Portal if you have not done so already: PRF Reporting Portal
- Work to close your books through June 30th. You will need to report your finalized financials to the HRSA portal. This is important for consistency in future periods and for auditing purposes.
- Familiarize yourself with the most recent FAQs: Provider Relief Fund FAQs
- Attached the HRSA Reporting webinar: HHS/HRSA Introduction to the PRF Reporting Portal
- Track your covid related expenses. The tracking of COVID-related expenses considered “not reimbursed” has the potential to be very extensive, detailed, and documentable. Please use our document as a guide or contact us to help complete it. Register to receive below.
- Organize your thoughts: Review and complete the attached document to help you organize and collect data needed for the reporting portal. Register to receive below.
- Register for Wipfli’s Healthcare Connections on July 14: Wipfli Healthcare Connections – Provider Relief Fund Reporting
- Sign up below to receive an engagement letter to assist with reporting requirements.
We expect continued clarification and guidance to be released in the coming weeks and will share additional insights as it becomes available. We are here to advise and can assist with all reporting requirements in the coming weeks and months. We will keep you apprised as more details unfold.