HHS Issues Provider Relief Fund Reporting Requirements Guidance
HHS issued guidance outlining the reporting requirements with which Provider Relief Fund (PRF) recipients that received one or more General Distribution or Targeted Distribution payments exceeding $10,000 in the aggregate (“PRF Recipients) must comply. The requirements do not apply to the Nursing Home Infection Control distribution of the Provider Relief Fund or the HRSA Uninsured Program. HHS plans to announce separate reporting requirements for the Nursing Home Infection Control distribution.
The guidance clarifies that PRF Recipients will report data used to determine (1) their healthcare-related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse; and (2) PRF payment amounts not fully expended on healthcare related expenses–represented as a negative change in year-over-year net patient care operating income, net of expenses that fall under #1. This second category of funds may be used to make up for lost revenues, up to a net zero gain/loss in 2020.
The PRF Reporting System will collect the following data from PRF Recipients:
– Demographic information, including reporting entity (TIN), NPI (optional), fiscal year-end date, and federal tax classification.- Expenses attributable to Coronavirus not reimbursed by other sources, including general and administrative expenses (including subcategories such as personnel, fringe benefits); and health care expenses (including subcategories such as supplies, equipment, IT, facilities). PRF Recipients of $500,000 or more are required to report more detailed information according to the list of subcategories enumerated in the guidance.
– Lost revenues attributable to Coronavirus Revenue. These data elements include total revenue/net charges from patient care related sources in 2019 and 2020; revenue from patient care payer mix for 2019 and 2020 (delineated by Medicare Part A+B, Medicare Part C, Medicaid, Commercial Insurance, Self-Pay, and Other); other assistance received including Treasury, Small Business Administration and Paycheck Protection Program funding, FEMA CARES Act funding, CARES Act Testing funding, local/state/tribal government assistance, business insurance, and “other assistance,” defined as the total amount of other federal and/or coronavirus-related assistance received by the recipient and other TINs included in its report as of the reporting end date”; and total calendar year expenses for 2019 and 2020, including a break-down of general and administrative expenses and healthcare related expenses.
– Additional non-financial data including facility, staffing and patient care metrics (e.g., total personnel, number of patient visits, number of available beds); change in ownership; and single audit status.
Notably, the guidance sets a new deadline by which PRF Recipients must expend PRF payments without returning funding to the federal government. The guidance indicates that “if recipients do not expend PRF funds in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts,” meaning that funds should be expended by the end of June. (The Provider Relief Fund FAQs indicate that HHS expects providers to fully expend their payments by July 31). HHS plans to launch the PRF Reporting System on October 1 and PRF Recipients are expected to submit the first reports regarding 2020 spending no later than February 15. For PRF Recipients with unexpended funds after December 31, 2020, a second and final report is due no later than July 31, 2021. HHS anticipates issuing FAQs and hosting webinar(s) in the near future.