Provider Relief Fund Reporting Requirements for Healthcare Providers
If you’re a healthcare provider and received funding from the Provider Relief Fund, the deadline for reporting the use of funds to the Health Resources & Services Administration is March 31, 2022.
Here’s what healthcare providers need to know.
Background of the Provider Relief Fund
The COVID-19 pandemic severely impacted the financial sustainability of healthcare providers. Due to shutdowns and limitations on elective procedures, healthcare providers lost out on significant revenues. Providers also incurred additional costs to keep patients and staff safe during the pandemic.
Knowing that healthcare providers are crucial for maintaining the health and safety of Americans, the federal government rolled out the Provider Relief Fund (PRF).
The PRF, which we originally looked at in this blog post, is primarily funded by several relief packages, including:
- Coronavirus Aid, Relief and Economic Security Act (CARES – $100 billion)
- Coronavirus Response and Relief Supplemental Appropriations Act (CCRSA – $3 billion)
- Payroll Protection and Health Care Enhancement Act (PPHCEA – $75 billion)
The PRF saved countless healthcare providers from financial uncertainty. However, the funds came with some strings attached.
Allowable Expenses Related to the Provider Relief Fund
The primary use of the funds is to cover expenses related to preventing, preparing for and responding to COVID-19.
It’s important to note that any expenses that were reimbursed by other programs, such as a Payroll Protection Plan loan or previous PRF payments, cannot be used in the calculation of acceptable PRF expenses. The eligible expenses for PRF fall under two categories: (1) general/administrative and (2) healthcare-related expenses attributable to COVID-19.
The following general and administrative expenses are allowable:
Payments related to mortgage or rent of a facility.
Business insurance premiums paid for property, malpractice, general business and other operation related insurance.
Workforce-related actual expenses paid to prevent, prepare for or respond to COVID-19, such as workforce training, staffing, temporary employees, contract labor, overhead/administration employees or security employees.
Additional benefits supplementing an employee’s salary such as hazard pay, travel reimbursement and employer health insurance.
New equipment or software leases for a vehicle, medical equipment or other COVID-19 related equipment that is not outright purchased and will be returned to the original owner (operating lease).
Lighting, cooling/ventilation, cleaning or other outside sourced services not included in personnel.
Other general and administrative expenses
Any other expenses that can be considered to prevent, prepare for or respond to COVID-19 that were not included in the other general and administrative expenses.
Additionally, the following healthcare-related expenses attributable to coronavirus are allowable:
Single-use or reusable patient care devices, cleaning supplies and office expenses used to prepare for, prevent or respond to COVID-19. Those supplies include PPE, hand sanitizer, supplies for patient screening and vaccination administration materials, among other things.
Caveats Related to Expenses
There are a few other caveats to note with the expenses.
The purchase of supplies is still eligible in the current reporting period even if the supplies do not arrive within the reporting period.
Additionally, a capital project is allowable only if the project is completed before the designated deadline to use the funds. You must also follow the same basis of accounting that your organization follows, so if your organization reports its books on the cash basis of accounting, the expenses in the reporting period must fall within that same basis of accounting.
If the allowable expenses do not cover the total amount of PRF funds received, the healthcare organization may use the remaining funds to cover lost profits in the reporting period.
There are three methods of determining lost profits. Once the method is accepted, it must be used across all PRF reporting periods. Just like the expenses, there must be consistency in accounting method when calculating lost revenue. The three methods are (1) 2019 revenue baseline, (2) budget versus actual and (3) other reasonable method.
If there is unused lost revenue not covered by PRF funds, the organization can use the remaining lost revenue amount in future reporting periods. The lost revenue calculation must be split into the following categories: Medicare A + B, Medicare Part C, Medicaid/Children’s Health Insurance Program, commercial insurance, self-pay (no insurance) and miscellaneous other sources of patient care service not included in the other categories.
Accounting Methods for Calculating Lost Revenue
Let’s take a closer look at the three accounting methods for calculating lost revenue:
2019 revenue baseline
This method is the most common and simple. It requires the organization to calculate lost revenue by comparing a quarter in the current reporting period to that same quarter in 2019.
Approved budget versus actual
This method calculates lost revenue by comparing budgeted revenue by payer type compared to the actual revenue the organization received in the budgeted period.
In order to use this method, the organization must have a budget that was approved prior to March 27, 2020, and cover the entire period of eligibility. Additionally, an attestation must be made by a CEO, CFO or other representative.
Other reasonable method (undefined)
With this method, the organization must submit a calculation for lost revenue based on a method deemed reasonable. Excel support for the method and an explanation must also be accompanied to support the calculation.
The Health Resources & Services Administration (HRSA) notes that there is a high likelihood of an audit if this method is used.
Reporting Period 2
We are currently in Reporting Period 2, which covers PRF funds received between July 1, 2020, and December 31, 2020.
If your organization received PRF funds during that period, the use of the funds must be reported to the HRSA between January 1, 2022, and March 31, 2022.
What You Should Do Now
If you received Reporting Period 2 funds, you must have completely expended those funds received under the HRSA guidelines by December 31, 2021.
In order to report the fund usage and other information to the HRSA, you will need to sign up on their portal. Once you register for one period, you will not be required to register for any other reporting periods for which you received PRF funds. Also, if the funds are not completely exhausted by the deadline, the provider must repay the unused balance to the HRSA by April 30, 2022.
It is important to understand your organization’s PRF reporting requirements. Failure to meet the reporting requirements in the allotted timeframe may result in you having to repay all funds and later, go through debt collection actions.
The HRSA provides PRF recipients with several resources:
- Reporting resources include reporting guides for Period 2, webinars for Period 2 reporting and reporting fact sheets
- PRF reporting hotline: 866.569.3522
Contact us here or call 800.899.4623.
Published on March 22, 2022