On January 15, the Department of Health and Human Services (HHS) opened the Provider Relief Fund Reporting Portal for registration only. The 200,000+ providers that received $10,000+ in PRF payments are directed to register and create an account, but no registration deadline has been announced.
HHS has abandoned its previously announced February 15 reporting deadline because the portal does not have reporting functionality. HHS will announce the new deadline once such functionality is available.
HHS has published a user guide and detailed FAQs regarding the registration process. HHS warns that the process will take at least 20 minutes and must be completed in one session (i.e., one cannot save partial information). The user guide includes screenshots detailing all information required for registration.
Also on January 15, HHS released the latest version of the Post-Payment Notice of Reporting Requirements. (This is the fourth version if you’re counting.) The Notice incorporates the changes made by the Consolidated Appropriations Act.
The Notice gives three options regarding the calculation of 2020 lost revenue: (1) the difference between 2019 and 2020 actual patient care revenue; (2) the difference between 2020 budgeted and 2020 actual patient care revenue, providing the budget was approved prior to March 27, 2020; or (3) any reasonable method of estimating revenue.
A provider electing option 3 must submit to HHS a description of its methodology, an explanation of why it is reasonable, and establish how the identified lost revenues were attributable to coronavirus. If HHS rejects the method, the provider will have 30 days to resubmit its report using option 1 or 2. HHS warns that recipients relying on option 3 face an increased likelihood of a future audit.
The Notice also details reporting responsibility for parent organizations and their subsidiaries. A subsidiary that received a targeted distribution and transferred some or all those funds to its parent organization still must report on the use of those funds, including the amount transferred. HHS warns that transferred targeted distributions also face an increased likelihood of a post-reporting audit.
PYA’s COVID-19 Task Force includes subject matter experts in regulatory compliance, accounting, audit, cost reporting, tax, operations, and strategy. We help health systems, hospitals, critical access hospitals, post-acute providers, and physician practices of all specialties navigate COVID-19 relief funding. Our team’s numerous presentations and publications have delivered direction and insight for providers struggling with complex, confusing, and sometimes contradictory federal guidance.
As your organization prepares to register and report, PYA can help with:
- Developing a defensible lost revenue calculation
- Re-allocating targeted distributions
- Interpreting and applying guidance regarding COVID-19-related expenses
- Properly accounting for other COVID-19 relief
- Resolving issues relating to portal reporting
- Developing appropriate documentation in the event of future audit
- Addressing COVID-19-related cost reporting issues
- Understanding and preparing to meet Single Audit requirements
If you have questions or need assistance, send an email to a PYA COVID-19 Task Force member below or call (800) 270-9629.