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HHS Updated Guidance on Reporting Requirements

Tiffany Karlin

September 22, 2020

This alert serves as an update to our prior guidance sent in August.

Over the weekend, The Health and Human Services posted brief guidance related to reporting requirements for the HHS General and Target Distribution Funds. Click here for the direct guidance from their website.

A synopsis of the report and what we know today:

When will the portal open to report?:

Key dates

  • January 15, 2021: reporting system opens for providers
  • February 15, 2021: first reporting deadline for all providers on use of funds
  • July 31, 2021: final reporting deadline for providers who did not fully expend PRF funds prior to December 31, 2020

Providers who these reporting requirements do NOT apply to:

  1. Nursing Home Infection Control Distribution Payments
  2. Rural Health Clinic Testing Distribution
  3. HHS Uninsured Portal

*Separate reporting requirements will be announced for these distributions.

Reporting Guidance Use of Funds:

  1. Healthcare expenses that are attributable to COVID that another source has not reimbursed and is not obligated to reimburse. Examples include General and Administrative (G&A) and/or other healthcare-related operating expenses
  2. Lost revenues represented as “a negative change in year-over-year net patient care operating income”, net of COVID-related healthcare expenses.
    1. Providers that reported negative net operating income from patient care in 2019 may apply funding amounts to lost revenues up to a net-zero gain/loss in 2020.

How long can I use the funds?

If providers do not use the total funds in full by year-end 2020, they will have an additional six (6) months to use the remaining amounts toward expenses or lost revenue in an amount not to exceed the 2019 net gain. Providers with unused funds 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.

Data Needed to Report:

Demographic Info:

  1. Reporting Entity: Entity that received one or more of the payments.
    1. “If the entity has subsidiary TINs that received General Distribution payments, regardless of whether the subsidiary or Reporting Entity formally attested to accepting the payment within the provider portal, the Reporting Entity may report on and direct the use of General Distribution payments. However, if a subsidiary TIN received a Targeted Distribution payment,1 the subsidiary TIN must report the use of funds for that payment, and the parent organization that reports on a subsidiary’s General Distribution payment cannot also report on (or transfer) the subsidiary’s Targeted Distribution payment.”
  2. Tax Identification Number: Reporting Entity’s primary TIN associated with the provider who received the funds and accepted the PRF payment during attestation (the recipient).
  3. National Provider Identifier (NPI)
  4. Fiscal/Calendar Year End Date
  5. Federal Tax Classification: S-Corp, C-Corpo, LLC, etc….

Expense Detail:

  1. Reporting Entities that received between $10,000 and $499,999 in aggregated payments are required to report healthcare-related expenses attributable to coronavirus, net of other reimbursed sources (e.g., payments received from insurance and/or patients, and amounts received from federal, state, or local governments, etc.) in two aggregated categories:
    1. G&A expenses and;
    2. other healthcare-related expenses.
  2. Reporting Entities that receive $500,000 or more in PRF payments the same as above but with more detailed information within the two categories of G&A expenses and other healthcare-related expenses.

General and Administrative Expenses:

  1. Mortgage/Rent: Monthly payments related to mortgage or rent for a facility.
  2. Insurance: Premiums paid for the property, malpractice, business insurance, or other insurance relevant to operations.
  3. Personnel: Workforce-related actual expenses paid to prevent, prepare for, or respond to the coronavirus during the reporting period, such as workforce training, staffing, temporary employee or contractor payroll, overhead employees, or security personnel.
    1. Note: No salary can exceed that of a rate of “Executive Level II” at $197,300. Further, salary limitation direct salary is exclusive of fringe benefits and indirect costs.
  4. Fringe Benefits: Extra benefits supplementing an employee’s salary, which may include hazard pay, travel reimbursement, employee health insurance, etc.
  5. Lease Payments: new equipment or software lease.
  6. Utilities/Operations: Lighting, cooling/ventilation, cleaning, or additional third party vendor services not included in “Personnel”.
  7. Other General and Administrative Expenses: Costs not captured above that are generally considered part of the overhead structure.

Healthcare Related Expenses:

  1. Supplies: Expenses paid for the purchase of supplies used to prevent, prepare for, or respond to the coronavirus during the reporting period. Such items could include personal protective equipment (PPE), hand sanitizer, or supplies for patient screening.
  2. Equipment: Expenses paid for the purchase of equipment used to prevent, prepare for, or respond to the coronavirus during the reporting period, such as ventilators, updates to HVAC systems, etc.
  3. Information Technology (IT): Expenses paid for IT or interoperability systems to expand or preserve care delivery during the reporting period, such as electronic health record licensing fees, telehealth infrastructure, increased bandwidth, and teleworking to support a remote workforce.
  4. Facilities: Expenses paid for facility-related costs used to prevent, prepare for, or respond to the coronavirus during the reporting period, such as lease or purchase of permanent or temporary structures, or to modify facilities to accommodate patient treatment practices revised due to coronavirus.
  5. Other Healthcare Related Expenses: Any other actual expenses, not previously captured above, that were paid to prevent, prepare for, or respond to the coronavirus.

Lost Revenues:

Lost revenues that are directly attributed to COVID, are identified as “a negative change in year-over-year net operating income from patient care related sources.” Revenues and expenses in this section include all lost patient care revenues and patient car cost/expense impacts.

Revenues and expenses in this section include:

1. lost patient care revenues and; 2. patient care cost/expense impacts.

Calculation:

Total Revenue/Net Charges from Patient Care5 Related Sources (2019 and 2020): Revenue/net charges from patient care (prior to netting with expenses) for the calendar years 2019 and 2020. Calendar year actual revenues will be entered by quarter (e.g., January–March 2019, April–June 2019, etc.).

Other:

       Facility, Staff and Patient Metrics:

  1. Personal: Total personnel by labor category (FT, PT, etc)
  2. Patient Visits
  3. Facility Metrics: available beds

Single Audit Requirements for those providers who received in aggregate of $750,000, continue to be enforced as detailed on our previous alert.

We know how crucial this time is for you. Our Mueller Prost Accounting and Reimbursement Healthcare Team is united to review this guidance, interpret, ask questions, and provide you with the necessary support to plan for the reporting deadlines.  As more details unfold on these reporting requirements, we will continue to update you with guidance, training, and proper support to file appropriate reporting when the time comes to do so.

In the meantime, feel free to reach out to me with questions.

Want more information regarding the HHS reporting requirements? Join us on October 14th at 1:00 pm CST for an upcoming webinar on single audits. Click here to register.

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