provider relief fund & rural health clinic reporting requirements update

Please note this information is updated through 11.9.2020. The reporting requirements are changing at a rapid pace – please continue to check for updates to the guidance as new information may change the information listed below:

Provider Relief Fund Reporting Requirements over $10,000

HHS released new/updated PRF FAQs on 10.28.2020 and then again on 11.2.2020. There is a significant amount of content added and implications for providers. We encourage providers and medical practices to review the new guidance in detail.

Highlighted FAQS:

1. Page 3 – If a provider returns a Provider Relief Fund payment to HHS, must it also return any accrued interest on the payment? (Added 10/28/2020)
2. Pages 8-9 – clarifies “health care-related expenses or lost revenues that are attributable to coronavirus” and outlines what expenses or lost revenues are considered eligible for reimbursement
3. Page 16-18 – When reporting my organization’s other health care-related expenses attributable to coronavirus, how do I calculate the “expenses attributable to coronavirus not reimbursed by other sources”? (Added 10/28/2020)
4. Page 18 – Do providers report total purchase price of capital equipment or only the depreciated value? (Added 10/28/2020)
5. Page 19 – Can I use 2020 budgeted revenues as a basis for reporting lost revenues? (Added 10/28/2020)
6. Page 20 – How does cost reimbursement relate to my Provider Relief Fund payment? (Added 10/28/2020)

Direct link to FAQs:  https://www.hhs.gov/sites/default/files/provider-relief-fund-general-distribution-faqs.pdf

Recommendations at this point:

1. Recommendation to track provider/service lines changes between 2019 and 2020, but unsure yet if this will be factored into the lost revenue calculation
2. Track expenses and ensure no double counting between programs – Be aware of the financial assistance received and various programs your practice received funding, track expenditures by fund.
3. Start documentation and gathering of information for the reporting requirements – first reporting due 2/15/2021
4. Review single audit implications if federal funds expended exceed the $750,000 threshold
5. Review your “lost revenue” calculation; use actual year to date 2020 versus actual 2019.

Full text of Reporting Requirements: https://www.hhs.gov/sites/default/files/post-payment-notice-of-reporting-requirements-november-2020.pdf

* These final reporting requirements do not apply to:

1. Nursing Home Infection Control distribution recipients
2. Rural Health Clinic Testing distribution recipients
3. Health Resources and Services Administration (HRSA) Uninsured Program reimbursement recipients

Rural Health Clinic (RHC) Distribution Reporting Requirements

A reminder to providers that the reporting portal is open for the $49,461.42 RHC testing distribution providers received from HHS starting back in May 2020. HRSA also updated its FAQs and clarified that reporting related to testing and spending must be reported monthly. The next deadline for reporting the October data is 11/30/2020. The PRF reporting requirements over $10,000 that are due 2/15/2021 do not apply to the RHC distribution.

RHC Reporting Deadlines

Monthly Data                                     Reporting Deadline

May – September 2020                  October 31, 2020

October 2020                                     November 30, 2020

November 2020                                December 31, 2020

December 2020                                 January 31, 2021

January 2021                                      February 28, 2021

HRSA FAQs – Rural Health Clinic COVID-19 Testing Program: https://www.hrsa.gov/rural-health/coronavirus/frequently-asked-questions#rhc

RHC Reporting Portal: https://www.rhccovidreporting.com/

Highlighted FAQs:

What information is required for RHC COVID-19 Testing Program reporting? (Added: 10/28/2020)

RHC COVID-19 Testing Program reporting includes basic information on the RHC organization, the number of and location of testing sites (active and inactive), information on the use of funds, the total number of tests conducted, and the number of COVID-19 positive tests. HRSA intends to use this information to evaluate the effectiveness of the program at an aggregate level. The reporting requirement does not include any personally identifiable, patient-level information.

How often do RHCs/TIN organizations need to update their information on RHCcovidreporting.com? (Added: 10/28/2020)

RHCs are required to provide information monthly.

What are permissible expenses under the $225 million Rural Health Clinic COVID-19 Testing Program payment? (Added: 5/20/2020)

Rural Health Clinic COVID-19 Testing Program funding may be used for COVID-19 testing and related expenses. As set forth in the Terms and Conditions (PDF – 223 KB), examples of related expenses include, but are not limited to, planning for implementation of a COVID-19 testing program, procuring supplies to provide testing, training providers and staff on COVID-19 testing procedures, and reporting data to HHS on COVID-19 testing activities. Further, the Rural Health Clinic COVID-19 Testing Program funds may be used for building or construction of temporary structures, leasing of properties, and retrofitting facilities as necessary to support COVID-19 testing.