True to its word, the Department of Health and Human Service (HHS) opened the Provider Relief Fund (PRF) Reporting Portal on July 1. Providers that received one or more payments exceeding $10,000 in the aggregate on or before June 30, 2020, must report by September 30, 2021. (Reporting on payments received after that June 30, 2020, date will be due at a later date.) HHS states it will not grant any extension of the reporting deadline, and those providers that fail to report will be “deemed out of compliance with program Terms and Conditions and may be subject to recoupment.”
Also on July 1, HHS posted a 73-page Reporting Portal User Guide (with many helpful screenshots) and Data Entry Worksheets on its PRF website to assist providers in preparing to report through the portal. HHS also announced a new Provider Support Line at (866) 569-3522 (available 8 am to 11 pm ET, Monday – Friday) for “technical questions regarding the use of the portal or questions regarding reporting that cannot be answered by…available resources.” Finally, HHS has scheduled a Reporting Technical Assistance Webcast for July 8, 2021, at 3 pm ET.
Access to the reporting portal is limited to those providers that have completed the registration process. Every time a user tries to log into the portal, a unique verification code will be sent to the contact email address provided during the registration. The user must enter this code along with a valid password to access the portal. Note the report must be completed and saved stepwise; one cannot skip steps. Data may be saved throughout the reporting process, so it is not necessary to complete the report in one session.
Here’s a quick step-by-step summary of the reporting process based on our review of the User Guide and Data Entry Worksheets. (Note: these steps do not correspond directly with the steps listed in the User Guide; we have condensed some steps and not included the slightly different reporting requirements for the Nursing Home Infection Control Distribution payments.)
Step 1: Entity Overview
Most of the information in this section is pre-populated from the registration process. However, the Reporting Entity must select the Provider Type and Provider Sub-Type that best describes the type of practice using dropdown menus. If multiple Provider Types or Provider Sub-Types apply, the Reporting Entity should choose the pair that reflects the majority of its business.
Step 2: Subsidiary Questionnaire
The purpose of this section is to collect information about the Reporting Entity’s subsidiary entities (if it is a parent organization) or parent entity (if it is a subsidiary) based on responses to four questions:
- Does the Reporting Entity have any subsidiaries that are eligible healthcare providers?
- Did the Reporting Entity acquire or divest subsidiaries that are eligible healthcare providers and that received PRF payments on or before June 30, 2020?
- If the Reporting Entity is a subsidiary, will a parent entity report on any of the Reporting Entity’s General Distribution payment(s)? If yes, the Reporting Entity will list the parent entity’s TIN.
- Were any Targeted Distribution payment(s) transferred to/by a parent entity? If yes, the Reporting Entity will enter the total dollar amount of Targeted Distribution payment(s) transferred to/by the parent entity (aggregate amount if transferred to more than one TIN).
If the Reporting Entity responds “Yes” to Question 2 above, it will be required to identify each acquired or divested subsidiary and provide specified details regarding the transaction.
Step 3: Payments to Recipient
In Step 3, the Reporting Entity must certify pre-populated information regarding the PRF payments received. If any information is inaccurate, the Reporting Entity must select “No” and list the reason the information is inaccurate. The Reporting Entity then must call the Provider Support Line to resolve the incorrect payment data. The Reporting Entity cannot proceed to the next step in the reporting process until the dispute is resolved.
Step 4: Interest Earned on PRF Payments, Tax Information, and Single Audit Information
Step 4 includes three distinct items. First, the Reporting Entity must report on the amount of interest earned on all PRF payments received on or before June 30, 2020, calculated from the date the payment was received until the date of expenditure or the date of return in the case of unused PRF payments.
Second, the Reporting Entity must select from dropdown menus its federal tax classification and its fiscal year-end date. And third, the Reporting Entity must complete the Audit Requirement table by indicating for fiscal years 2019, 2020, and 2021, whether the recipient was subject to a single audit and whether PRF payments were included in the audit.
Step 5: Other Assistance Received
A Reporting Entity must list for each calendar quarter (Q1 2020 to Q2 2021) other assistance it received (including its subsidiaries) across the following categories:
- Department of the Treasury and/or Small Business Administration Assistance (including the Paycheck Protection Program)
- Federal Emergency Management Agency (FEMA) Programs
- HHS CARES Act Testing
- Local, State, and Tribal Government Assistance
- Business Insurance
- Other
In a July 1 FAQ, HHS clarified that “[p]atient care revenue should not be reported as part of ‘Other Assistance Received’ as it is a source of revenue, not a source of other assistance as defined by Provider Relief Fund reporting requirements.”
The information reported in this section will not be used to calculate lost revenue or expenses. Instead, “Reporting Entities are expected to make a determination of their expenses applied to PRF payments after considering Other Assistance Received and taking into account that PRF payments may not be used for expenses or lost revenues that other sources have reimbursed or that other sources are obligated to reimburse.”
Step 6: Expenses for PRF Payments Received
In this section, the Reporting Entity will list the quarterly expenses reimbursed with PRF payments. Reporting Entities that received between $10,001 and $499,999 in aggregated PRF payments on or before June 30, 2020, are required to report on the use of PRF payments in two categories: (1) General and Administrative (G&A) Expenses, and (2) Healthcare-Related Expenses. Those receiving $500,000+ in aggregated payments must report by specified sub-categories under G&A Expenses and Healthcare-Related Expenses.
HHS stated unequivocally that it will not permit any extension on the use of funds beyond June 30, 2021. In a July 1 FAQ, however, HHS stated “[f]or purchases of tangible items made using [PRF] payments, the purchase does not need to be in the Reporting Entity’s possession (i.e., backordered personal protective equipment, capital equipment) to be considered an eligible expense. However, the costs must be incurred [by June 30, 2021]. Providers must follow their basis of accounting (e.g., cash, accrual, or modified accrual) to determine expenses.”
Step 7: Unreimbursed Expenses Attributable to Coronavirus
A Reporting Entity must list by calendar quarter those expenses attributable to coronavirus in excess of PRF payments. HHS states this data will not be used in the calculation of expenses or lost revenue but does not indicate for what purpose it will be used. Hopefully, HHS will consider these unreimbursed expenses in making additional PRF distributions, given billions remain undistributed to providers.
Step 8: Actual Patient Care Revenue or Lost Revenues
If the Reporting Entity’s reported expenses attributable to coronavirus are greater than the total amount received in PRF payments (plus interest), the Reporting Entity will report its actual patient care revenue for calendar years 2019 and 2020 in this section. If any amount remains, the Reporting Entity will select the method by which it will report lost revenues in the next step.
Step 9: Lost Revenues
There are three methods by which a Reporting Entity may calculate and report lost revenue: 2019 actual revenue, 2020 budgeted revenue, and an alternate method. The method selected in Step 9 will determine the information the Reporting Entity must provide in this section.
A. 2019 Actual Revenue
The Reporting Entity must provide actual patient care revenue by calendar quarter for 2019, 2020, and 2021 (Q1 and Q2) by payer (traditional Medicare, Medicare Advantage, Medicaid/CHIP, commercial, self-pay).
HHS states “lost revenues will be calculated for each quarter during the period of availability, as a standalone calculation, with 2019 quarters serving as a baseline. For each calendar year of reporting, the applicable quarters where lost revenues were demonstrated are totaled to determine an annual lost revenues amount. The annual lost revenues are then added together to determine a total that can be applied to PRF payments.” Based on this statement, it appears HHS will not offset lost revenue by amounts in excess of prior year performance. In our experience, this apparent change may eliminate the need to use the alternate method for many providers.
B. 2020 Budgeted Revenue
Under this method, the Reporting Entity must provide budgeted and actual patient care revenue by calendar quarter for 2020 and 2021 by payer. The Reporting Entity also must submit a copy of the 2020 budget approved prior to March 27, 2020, and attestation as to the “accuracy” of the budget. There is no requirement to submit a 2021 budget; in fact, the User Guide is the first mention of a comparison between the 2021 budget and actual for purposes of calculating lost revenue.
HHS states “lost revenues that can be applied to PRF payments will be calculated by quarter for each quarter during the period of availability, as a standalone calculation, with 2019 quarters serving as a baseline. For each calendar year of reporting, the applicable quarters where lost revenues are demonstrated are totaled to determine an annual lost revenues amount. The annual lost revenues are then added together to determine a total that can be applied to PRF payments.” This appears to be an error, however, because this method does not require reporting on 2019 actual revenue. Instead, one should assume the calculation is based on a comparison of actual to budget for each quarter. And again, it appears HHS will not offset lost revenue by amounts in excess of budget.
C. Alternate Method
A Reporting Entity that elects to use an alternative method for calculating lost revenue must provide lost revenue values by calendar quarter for 2020 and 2021, along with a narrative explanation (with supporting documentation) of the methodology used in making these calculations.
If HHS determines the method is not reasonable, it will notify the Reporting Entity, which will have 30 days to resubmit using the 2019 actual revenue or 2020 budgeted revenue methodology. HHS also warns that “[a]ll recipients seeking to use an alternate methodology face an increased likelihood of an audit….”
Step 10: Financial Summary
Based on the data input by the Reporting Entity, the portal calculates the total amount of PRF payments used by the Reporting Entity and the difference between the amount received and the amount used. If any information appears inaccurate, the Reporting Entity can navigate back to prior sections and correct data previously entered, but it cannot make changes to the Financial Summary itself.
Step 11: Personnel, Patient, and Facility Metrics
The Reporting Entity must report certain personnel, patient, and facility metrics in this section. To complete the personnel metrics data tables, a Reporting Entity must calculate by calendar quarter the total number of people employed in clinical and non-clinical positions (across all TINs included in the reporting) by labor category (full-time, part-time, contracted, furloughed, separated, and hired).
For the patient metrics data tables, a Reporting Entity must list the following information by calendar quarter for 2020 and 2021: inpatient admissions, outpatient visits (in-person and virtual), emergency visits, and facility stays (for long- and short-term residential facilities). Finally, if the Reporting Entity and/or its subsidiaries operate or support staffed beds, it must list the number of medical/surgical beds, critical care beds, and other beds by calendar quarter for 2020 and 2021.
Step 12: Survey
To complete the reporting process, the Reporting Entity must submit its responses to survey questions regarding the financial and clinical care effects of PRF payments. The survey includes an opportunity to provide narrative feedback (limited to 1,000 characters) “regarding both positive impact of the payments, limitations of the payments, and other comments or concerns that relate to the applicable PRF payments.”
Step 13: Review and Submit
After having completed all prior steps, the Reporting Entity will be asked to review and submit its report. If the report indicates the Reporting Entity has unused PRF payments, the user will be directed in red text to follow the instructions located on the PRF website to return unused funds.
When one clicks on “Submit,” the following warning appears:
“After clicking ‘Submit,’ you acknowledge and accept that you will no longer be able to edit, update, or modify the data you have submitted. Once submitted, all submittals are final and cannot be edited and will be used…to validate and verify your compliance with the Terms and Conditions.”
Join PYA for our Provider Relief Fund Reporting Requirements webinar July 21, 2021, at 11 am ET. Members of PYA’s PRF Task Force will take a deeper dive into some of the more challenging aspects of the reporting process. And watch this space for additional insights as we learn more.
If you have questions or need assistance related to PRF reporting, or need additional COVID-19 guidance, visit PYA’s COVID-19 hub, or contact a PYA executive below at (800) 270-9629.
