A month before the reporting deadline, the U.S. Department of Health and Human Services announced it would be pushing back the CARES Act Provider Relief Fund (PRF) reporting timeline now that the Coronavirus Response and Relief Supplemental Appropriations Act of 2021 has been passed. HHS has been working on updated reporting requirements that comply with this legislation.
HHS has also provided updated reporting guidance, allowing recipients to define lost revenue as one of three options. In the first, the difference between 2019 and 2020 actual patient care revenue, providers must submit 2019 Revenue from Patient Care Payer Mix by quarter as outlined in the guidance.
In using the difference between 2020 budgeted and 2020 actual patient care revenue, providers must submit a copy of their 2020 budget and an attestation from the chief executive officer or similar official that the budget was approved before March 27, 2020.
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For the third option -- any reasonable method for estimating revenue – providers must include a description and explanation of the alternative methodology, and will be at increased risk of a Health Resources and Services Administration (HRSA) audit. They will be notified if HRSA determines the proposed methodology is not reasonable and given 30 days to resubmit their report using one of the other two methods.
Recipients that do not expend all of their PRF distributions in 2020 will be allowed to use the remaining amounts through the first six months of 2021 on COVID-19-related expenditures or lost revenues. The revenue loss definition for the first six months of 2021 is either the difference between 2019 Q1-Q2 and 2021 Q1-Q2 actual revenue, or 2020 Q1-Q2 budgeted revenue and 2021 Q1-Q2 actual revenue.
WHAT'S THE IMPACT?
Beginning last summer, HHS began outlining comprehensive reporting instructions that would apply to recipients of PRF funds that received payments exceeding $10,000 in aggregate. HHS had previously planned to open the reporting portal based on this previously released information by January 15, with the first deadline for submissions on February 15, 2021.
But in late December Congress passed the Coronavirus Response and Relief Supplemental Appropriations Act, which added another $3 billion in funding to the PRF program and included language specific to reporting requirements. According to HHS, it has been working to update the PRF reporting requirements to be consistent with this new law.
That said, as HHS has done in the past, the department wanted to give recipients time to familiarize themselves with the updated reporting requirements in advance of required submission deadlines.
Yet in the interim, HHS is encouraging all PRF recipients that have received aggregate PRF payments that exceed $10,000 to establish a reporting account by registering at the newly enabled PRF reporting website.
The reporting requirements do not apply to funds from Nursing Home Infection Control, Rural Health Clinics Testing, and COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment and Vaccine Administration for the Uninsured recipients.
While there is currently no deadline for providers to establish a reporting account in the Reporting Portal, all providers will be required to complete that first step in order to advance and fulfill their reporting requirements once HHS announces the new deadline to do so. Provider support and call center resources are currently limited but available once the second phase for submissions is unveiled.
THE LARGER TREND
As of the week of January 11, HHS has made $116,956,445,191 in payments, through both the General and Targeted Distributions of the PRF program, to 644,091 provider TINs. A TIN is an IRS-assigned Federal Tax Identification Number. Of these payments, 403,235 providers (unique TINs) have attested to the terms and conditions for $101,933,833,186 in payments.
As of January 13, HHS has made COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing and Treatment of the Uninsured payments to 30,074 providers including $1,455,529,631 in testing claims and $1,557,659,437 in treatment claims.