June 11, 2021

Today, the U.S. Department of Health and Human Services, through the Health Resources and Services Administration (HRSA) released revised reporting requirements for recipients of Provider Relief Fund (PRF) payments. The revised reporting requirements will be applicable to providers who received one or more payments exceeding, in the aggregate, $10,000 during a single Payment Received Period from the PRF General Distributions, Targeted Distributions, and/or Skilled Nursing Facility and Nursing Home Infection Control Distributions.

For more information, read the materials below:

• HHS Press Release
• Post-Payment Notice of Reporting Requirements
• Provider Relief Fund Reporting Requirements and Auditing
• WSJ article on this announcement

Article below just popped into my inbox.  Below the article is the HHS Press Release re:  Updated HHS Provider Relief Funds Requirements doc that went public this afternoon.   Don’t forget to see the chart at the end of the Release.

My initial read is that the updated PRF requirements that came out today apply to ANY healthcare provider that received PRF in excess of 10,000 in aggregate received,  not just hospitals and health systems.  I think the focus on hospitals in the article below is due to the primary audience that subscribes to Modern Healthcare. 

Deadline to spend HHS relief funds extended for some providers

TARA BANNOW JESSIE HELLMANN , MODERN HEALTHCARE

HHS announced Friday four separate deadlines for when providers will have to spend or return unused Provider Relief Fund grants to the federal government, depending on when those payments were originally received. The final deadline is for funds received through the end of 2021.

“It’s a lot of good news, especially in terms of the deadline to use the funds,” said Kinman Tong, a healthcare partner with Moss Adams. “I think that’s the biggest ask and request by a lot of the providers out there.”

Providers who received PRF payments between April 10 and June 30, 2020 will still have to return any unused funds by June 30. Providers who received funds after June 30, 2020 will have staggered deadlines for using that money through the end of 2022.

“The staggered approach is definitely more welcome than the general June 30 deadline for everybody,” said Claire Ernst, associate director of government affairs for MGMA.

The American Hospital Association and other groups had called on HHS to extend the original June 30 deadline for spending funds through the end of the public health emergency, but appeared content with the announcement Friday.

“The AHA thanks HHS for listening to our concerns and extending the deadline for hospitals, health systems and other health care providers to use this critical relief funding,” AHA CEO Rick Pollack said in a statement. “Today’s announcement to give some health care providers more time to spend emergency coronavirus funding will help to ensure that hospitals and health systems can continue the battle against COVID-19 as cases persist.”

Providers now have 90 days after the deadlines to meet the reporting requirements, instead of the original 30 days. The reporting portal is set to open July 1.

Still, HHS has not issued any guidance on when the remaining $24 billion in the PRF will be released, including $8.5 billion recently appropriated by Congress for rural providers.

Previous guidance from January broke spending into a first and second round, the first covering all of calendar 2020 and the second covering the first six months of 2021. The new guidance outlines four separate periods in which providers must use and report the funds based on when they were received.

Rick Kes, RSM’s healthcare industry senior analyst, foresees that getting complicated from an accounting standpoint. Previous guidance didn’t require providers to spend money based on when they received it.

“It’s not that they can’t do it, but it’s going to cause more burden on them from a record-keeping perspective,” he said.

The most significant change in Friday’s updated guidance is the new spending and reporting schedule that’s now broken into four periods, said Aparna Venkateswaran, a senior manager with Moss Adams.

Another big change affects providers who received SNF and Nursing Home Infection Control Distribution payments. They must report those along with their Provider Relief Fund grants. That previously had been excluded from the PRF reporting, she said.

The new guidance leaves the reporting requirements largely unchanged. Tong said he thinks the 3-month deadline for reporting after the money is spent should be easy for hospitals to meet. That will be especially true after July 1, when the reporting portal opens and they have a better sense for what it looks like and how to use it, he said.

Providers will still have three options for calculating lost revenue. They can apply the grant toward lost revenue up to the difference between actual patient care revenue; use the difference between budgeted and actual; or calculate lost revenue by any reasonable method.

If providers select the second option, they now will need an executive explicitly attest that their budget had been in place prior to March 27, 2020. Under the third option, providers need a narrative description and calculation and demonstrate the lost revenue was due to COVID and not some other source, Venkateswaran said. If HRSA doesn’t accept the providers’ rationale, they’ll have to go back to the drawing board and use option 1 or 2.

Venkateswaran warned that providers using option three will face an increased likelihood of a HRSA audit.

“Providers that end up using option 3, that’s going to need more care and thought into what they document and what they provide to support that,” she said, “because that will have more scrutiny.
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From the HHS website:

HHS Issues Revised Notice of Reporting Requirements and Reporting Timeline for Recipients of Provider Relief Fund Payments

Today, the U.S. Department of Health and Human Services, through the Health Resources and Services Administration (HRSA) is releasing revised reporting requirements for recipients of Provider Relief Fund (PRF) payments. This announcement includes expanding the amount of time providers will have to report information, aims to reduce burdens on smaller providers, and extends key deadlines for expending PRF payments for recipients who received payments after June 30, 2020. The revised reporting requirements will be applicable to providers who received one or more payments exceeding, in the aggregate, $10,000 during a single Payment Received Period from the PRF General Distributions, Targeted Distributions, and/or Skilled Nursing Facility and Nursing Home Infection Control Distributions.

“From the beginning of this pandemic, health care providers have gone above and beyond to care for their patients in extremely difficult circumstances that caused significant financial hardship,” said HRSA Acting Administrator Diana Espinosa. “These updated requirements reflect our focus on giving providers equitable amounts of time for use of these funds, maintaining effective safeguards for taxpayer dollars, and incorporating feedback from providers requesting more flexibility and clarity about PRF reporting.”

HHS began issuing notices on post-payment reporting requirements in July 2020. On January 15, 2021, HHS issued updated requirements to reflect language in the Coronavirus Response and Relief Supplemental Appropriations Act of 2021 and opened registration for the reporting portal. Since then, HHS has carefully weighed the rapidly evolving nature of the pandemic and its impact on health care providers and other stakeholders, which is reflected in the revised notice issued today.

The revised reporting requirements supplanting the January 15th requirements can be found here – PDF.

Key Updates:

• The period of availability of funds is based on the date the payment is received (rather than requiring all payments be used by June 30, 2021, regardless of when they were received).
• Recipients are required to report for each Payment Received Period in which they received one or more payments exceeding, in the aggregate, $10,000 (rather than $10,000 cumulatively across all PRF payments).
• Recipients will have a 90-day period to complete reporting (rather than a 30-day reporting period).
• The reporting requirements are now applicable to recipients of the Skilled Nursing Facility and Nursing Home Infection Control Distribution in addition to General and other Targeted Distributions.
• The PRF Reporting Portal will open for providers to start submitting information on July 1, 2021.

Summary of Reporting Requirements

These reporting requirements do not apply to the Rural Health Clinic COVID-19 Testing Program nor the two claims reimbursements programs: the HRSA COVID-19 Uninsured Program and the HRSA COVID-19 Coverage Assistance Fund. HRSA continues to encourage providers to establish their PRF Reporting Portal accounts now by registering here. Registration will also allow providers to receive updates closer to the official opening of the portal for their reporting submissions.