Home Blog Hhs Provider Relief Fund Reporting Requirements Released

HHS Provider Relief Fund Reporting Requirements Released

HHS has released additional details regarding the post-payment reporting requirements for the HHS Provider Relief Fund. Any provider who received a payment or payments from any round or phase (Medicare or Medicaid) of the $50B General Distribution totaling more than $10,000 are required to submit reports showing how the money was used. As a reminder, if the funds are used properly, the money does not need to be repaid to HHS. Providers will need to report data elements from 2019 and 2020 as outlined below:  
  • Healthcare-related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse, which may include General and Administrative (G&A) or healthcare-related operating expenses. 
  • PRF payment amounts not fully expended on healthcare-related expenses attributable to coronavirus are then applied to lost revenues, represented as a negative change in year-over-year net patient care operating income (i.e., patient care revenue less patient care related expenses for the provider that received funding), net of the healthcare-related expenses attributable to coronavirus. Recipients may apply PRF payments toward lost revenue, up to the amount of their 2019 net gain from healthcare-related sources. Recipients that reported negative net operating income from patient care in 2019 may apply PRF amounts to lost revenues up to a net zero gain/loss in 2020.

If a provider has used all relief fund dollars by the end of 2020, they will only have to submit one report, and will have until Feb. 15, 2021 to do so. If they have unused funds leftover at the end of 2020, they will have until the end of June to utilize the remainder of the funds and will have to submit a second report on fund usage by July 31, 2021. Any funds that remain unused at the end of June will likely need to be returned to HHS.

Providers will need to submit demographic info, including reporting entity name, TIN, NPI, fiscal year end date, and federal tax classification. They will also have to summarize the expenses they incurred that were attributable to COVID-19 that were not or will not be reimbursed by another source in 2020. Expenses that are incurred while treating confirmed or suspected cases of COVID-19, preparing for potential cases of COVID-19, maintaining your capacity to provide your healthcare service, etc. are all considered expenses attributable to coronavirus. They will also have to report lost revenues attributable to coronavirus, and finally some non-financial data.
 
The amount you received from HHS will determine your overall reporting requirements. If you received between $10,000 and $500,000 you will only need to provide aggregated data in 2 categories: 1) General and Administrative (G&A) and 2) other healthcare-related expenses. Only expenses that have not or will not be reimbursed by another source will be considered, so these expenses cannot include payments received from insurance companies, patients, or any federal, state, or local governments. 
 
If you received $500,000 or more from the HHS Provider Relief fund, you will still report those same two expense types: G&A expenses and other healthcare-related expenses, but you will need to be more detailed in your reporting. The expenses data will need to be somewhat itemized rather than aggregated. For example, in the G&A expenses category, you will need to report expenses in each of
the following categories that are above and beyond what has been reimbursed by other sources:
  • Mortgage or rent expense
  • Insurance
  • Personnel (payroll expenses including temporary or contract employees)
  • Fringe benefits (hazard pay, travel reimbursement, health insurance, etc.)
  • Lease payments (new equipment, software, etc.)
  • Utilities and Operations (lighting, cooling, ventilation, cleaning, or other third party vendor services that aren’t part of payroll expenses)
  • Other G&A Expenses (overhead expenses not accounted for in the above categories)
For the healthcare-related expenses attributable to coronavirus expense category, providers will need to provide more detailed cost reporting in the following categories (again, costs that are above and beyond that have been or will be reimbursed by other sources):
  • Supplies (PPE, sanitizers, patient screening supplies, etc. used to prevent, prepare for, or prevent coronavirus)
  • Equipment (can be equipment used to help care for patients or equipment to make your facility a safer environment such as an upgraded HVAC or ventilation system)
  • Facilities (lease or purchase of permanent or temporary structures, facility modification expenses, etc.)
  • IT expenses
    • Expand or preserve care delivery during the pandemic
    • EHR licensing fees
    • Telehealth infrastructure
    • Increased bandwidth
    • Teleworking/remote workforce expenses
  • Other expenses not captured in the categories above
Providers will also need to submit information that will be used to calculate lost revenues attributable to coronavirus, represented as a negative change in year-over-year net operating income from patient care. A calendar year comparison of 2019 to 2020 healthcare expenses will be conducted to determine the impact on net operating income. Revenues and expenses in this section include all lost patient care revenues.
 
Providers can visit https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html and https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements.pdf for full details regarding these reporting requirements. HHS will likely conduct a webinar for providers, and will also continue to update the FAQs as more information is released.
 
Please reach out to Craig Douglas at VGM ([email protected] or 319-290-3535) or Mark Higley ([email protected] or 888-224-1631) if you have any questions regarding the HHS Provider Relief Fund.

0 comments