Medical Providers to Follow These New PRF Reporting Requirements
If you are a medical provider that received more than $10,000 in Provider Relief Fund payments, then this message is for you.
As of Saturday, September 19, 2020, the United States Department of Health and Human Services (HHS) released its Provider Relief Fund (PRF) Reporting Requirements detailing how medical providers who received more than $10,000 in PRF payments will be obligated to follow post-payment reporting requirements to report their use of funds.
What Information Needs to be Reported?
Providers will report healthcare-related expenses for both calendar years 2019 and 2020, and must categorize these expenses into General and Administrative expenses or healthcare-related operating expenses. Furthermore, medical providers are urged to include only those expenses that were not compensated for by other sources in this post-payment reporting process.
If all PRF payments were not exhausted by COVID-19 healthcare-related expenditures, providers can apply payments toward lost revenues. HHS defines lost revenues as “a negative change in year-over-year net patient care operating income.” Please note that this updated approach is more limited than the previous HHS guidance which allowed for “any reasonable method of estimating lost revenue.” HHS also caps the lost revenue application of PRF payments up to either the amount of a provider’s 2019 net gain from healthcare-related sources or up to a net zero gain/loss in 2020, if the provider reported negative net operating income in 2019.
Supplementary material that is also being requested by the HHS include, but are not limited to the following:
- Demographic information: Entity, TIN, fiscal year end date, federal tax classification
- Other forms of assistance received: Paycheck Protection Program funds, FEMA CARES Act payments, and state and local government financial aid
- Non-financial data (per quarter):
- Facility, staffing, and patient care:
- Personal metrics: total personnel by labor category, hire/re-hires, separations, etc.
- Patient metrics: total number of admits, visits, and residents.
- Facility metrics: total available staffed beds, etc.
- Change in ownership
- Single audit status
- Facility, staffing, and patient care:
*Reporting requirements do not apply to the Nursing Home Infection Control Distribution.*
Dates to Know and Next Steps
- January 15, 2021: Reporting system opens for providers.
- February 15, 2021: Deadline to submit first report due for PRF expenses incurred through December 31, 2020.
- July 31, 2021: Cutoff date to submit second and final report for incomes and expenses incurred between January 1, 2021 and June 30, 2021.
Medical providers are free to use PRF dollars through June 2021, but this window may change depending on whether Congress issues additional monetary aid for the PRF or if the Public Health Emergency (PHE) is prolonged past October 23, 2020.
Wish to talk more about what this means for your medical practice? Reach out to one of our medical practice consulting experts by clicking on the button below. We are always happy to help!