- The wait to learn how providers can report Provider Relief Fund (PRF) distributions finally ended when the PRF portal was opened by the federal government on July 1, 2021.
- Although HHS has opened the reporting portal, providers must register before starting the 16-step submission process.
- While providers may have been gathering expenditure data throughout the pandemic to report to HHS, the reporting portal also requires additional information that providers may have overlooked or that may not be easily accessible.
Healthcare providers are familiar with the concept of a waiting room, and they have been in one metaphorically speaking as the rules for how to utilize and report Provider Relief Fund (PRF) distributions have evolved over the past year. The wait just recently ended. The U.S. Department of Health and Human Services (HHS) released the latest PRF Post-Payment Notice Reporting Requirements (PPNRR) as of June 11, 2021. Following that communication, the federal government opened the long-awaited PRF portal on July 1, 2021, finally giving healthcare providers a tool with clearer instructions for reporting how their PRF distributions were utilized. HHS has also issued updates to the PRF frequently asked questions through July 15.
With these developments, there is a lot of updated information that providers need to be aware of and take into consideration. This communication summarizes the key components that will help providers navigate their PRF reporting strategy and related audit requirements.
Post-payment reporting requirements summary
Many healthcare providers have been monitoring the evolution of the reporting requirements throughout the past year and may have a sense of what is expected. There are, however, important changes with the latest update to the requirements, including:
- Portal reporting requirements are applicable if payments in excess of $10,000 were received in a reporting period.
- Portal reporting requirements apply to general and targeted distributions, including Skilled Nursng Facility (SNF) and Nursing Home Infection Control distributions.
- The reporting entity for targeted distributions is the entity that received the distribution. A parent entity cannot report on its subsidiaries’ targeted distributions, even if distributions were transferred to/from the parent entity.
- Expenses incurred to prevent, prepare for and respond to the coronavirus that were not reimbursed (or obligated to be reimbursed) by other sources are eligible expenses and are considered first in the usage of funds.
- Eligible expenses are categorized as either general and administrative or healthcare-related, with more granular reporting by subcategory for providers that received more than $500,000 in distributions.
- Recipients are required to report any interest earned on distributions received.
- SNF and Nursing Home Infection Control distributions can be used only for qualifying expenses; lost revenue is not an appropriate usage of these targeted distributions.
- If all PRF distributions are not used on eligible expenditures, then the reporting entity can calculate lost revenues using one of three options:
Option 1 –the difference between actual patient care revenues by calendar quarter, as compared to corresponding patient care revenues in 2019.
Option 2 – the difference between budgeted patient care revenue compared to actual, by calendar quarter, utilizing a budget approved prior to March 27, 2020.
Option 3 – any other reasonable method, which will be subject to a higher level of scrutiny and potential audit by HHS.
The final post-payment notice also established four separate reporting periods, based on when a recipient received funds. The following chart outlines the reporting schedule: