As we all have experienced over the last several months, the Provider Relief Fund (PRF) Reporting Requirements are constantly evolving. Below is an outline of recent changes to the PRF and a summary of where we are now. The goal is to help providers stay up to speed on current developments and offer insights on next steps.

Next Steps/Takeaways

• Register in the PRF Portal if you have not done so already
• Monitor the PRF guidance as to new reporting due date (not announced as of 2.10.2021)
• Determine methodology of lost revenue calculation your facility wants to pursue, organize, and accumulate data, calculation, and support as needed
• Create a global expense tracking document to accumulate COVID expenses and the funding stream you are claiming the expense under. This should be an actionable document the provider can review once the reporting portal is open. File should include:
  • COVID related expenses
  • Invoice number/payroll support
  • General ledger account number
  • Narrative/support for intent of the purchase/why is it allowable under the PRF program rules
  • The funding source the expense will be claimed under as an internal control on verifying that the expense has not been claimed under two programs (double-dipping)
  • Include other sources of reimbursement that will need to be offset against the COVID expenses.
• Assess single audit implications

Recent Updates

December 2020:

• Consolidated Appropriations Act (CAA) was signed including clarification on the PRF and lost revenues

January 15, 2021:

• The HHS PRF reporting portal was supposed to open 1/15/2021.
• The HHS website was updated with the portal where providers can register; however, the reporting section is not updated/open.
• HHS announced the 2/15/2021 reporting deadline has been extended, but HHS has not published the new deadline.
• HHS released updated reporting requirements in response to the CAA being signed
  • Various options on how to calculate lost revenue
    • difference between 2019 and 2020 actual patient care revenue
    • difference between 2020 budgeted and 2020 actual patient care revenue (budget must be approved prior to 3/27/2020 - providers will need to submit additional documentation)
    • calculated by any reasonable method of estimating revenue (providers must submit methodology/support for calculation - increased likelihood of an audit by HRSA)
  • These PRF Reporting Requirements do not apply to:
    • Nursing Home Infection Control distribution. If you received payment from the Nursing Home Infection Control distribution, you should still register in the PRF Reporting Portal.
    • Rural Health Clinic Testing distribution. If your only PRF payment was the Rural Health Clinic Testing Distribution, you should not register in the PRF Reporting Portal. For information about the Rural Health Clinic Testing reporting requirements, contact RHCCOVID-19Testing@hrsa.gov and learn more at the Rural Health Clinic Testing website. https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questions#rhc.
    • HRSA’s COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program.
  • In January, HHS made additional payments to providers through the general and targeted distributions along with COVID-19 claims reimbursement for testing/treatment of uninsured patients
  • Recent highlighted FAQs from the HHS Website:
    • Can I use 2020 budgeted revenues as a basis for reporting lost revenues? (Modified 1/28/2021) When reporting use of Provider Relief Fund money toward lost revenues attributable to coronavirus, Reporting Entities may use budgeted revenues if the budget(s) and associated documents covering calendar year 2020 were established and approved on or before March 26, 2020. To be considered an approved budget, the budget must have been ratified, certified, or adopted by the Reporting Entity’s financial executive or executive officer as of that date, and the Reporting Entity will be required to attest that the budget was established and approved on or before March 26, 2020. Documents related to the budget, including the approval, must be maintained in accordance with the Terms and Conditions.
    • If an entity incurred enough lost revenue in April and May 2020 to justify its use of the Provider Relief Fund payments received, can it only report those two months? (Modified 1/28/2021) Recipients have multiple options to calculate lost revenue as outlined in the Post-Payment Notice of Reporting Requirements. However, for each of these options, the Reporting Entity must report revenue for the full calendar year 2020. If funds were not expended in full by December 31, 2020, then a second and final report will be required on use of funds for the period January 1, 2021 - June 30, 2021, which is due no later than July 31, 2021.
    • If a provider administers a COVID-19 vaccine to a patient that has Medicare Part A, but not Part B, coverage, can the provider use Provider Relief Fund payments to cover the unreimbursed costs associated with vaccine administration? (Added 1/28/2021) The costs associated with administering a vaccine to a patient with Medicare Part A, but not Part B, coverage would be considered unreimbursed under the Provider Relief Fund. Payments could be used to cover incurred expenses.
    • Can Provider Relief Fund payments be used to support COVID-19 vaccine distribution? (Modified 1/28/2021) Provider Relief Fund payments may be used to support expenses associated with the distribution of a COVID-19 vaccine licensed or authorized by the Food and Drug Administration (FDA) that have not been reimbursed from other sources or that other sources are not obligated to reimburse. Funds may also be used ahead of an FDA-licensed or authorized vaccine becoming available. This may include using funds to purchase additional refrigerators or freezers, personnel costs to provide vaccinations, and transportation costs not otherwise reimbursed.

Resources:

Post-Payment Notice of Reporting Requirements - https://www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements-january-2021.pdf

Reporting Requirements and Auditing Homepage - https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html

Press Release – HHS Announces PRF Reporting Update - https://www.hhs.gov/about/news/2021/01/15/hhs-announces-provider-relief-fund-reporting-update.html

PRF Reporting Portal HHS Page - https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html

Direct Link to PRF Portal - https://prfreporting.hrsa.gov/s/