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HHS Expands Options for Reporting Lost Revenues Due to Coronavirus

01.19.2021

On January 15, HHS published a new reporting requirements document that updated their previous guidance from November 2, 2020. HHS has provided three options for providers to consider who have received over $10,000.

HHS states, “Recipients may choose to apply PRF payments toward lost revenue using one of the following options, up to the amount:

a) of the difference between 2019 and 2020 actual patient care revenue;

b) of the difference between 2020 budgeted and 2020 actual patient care revenue. If recipients elect to use 2020 budgeted patient care revenue to calculate lost revenue, they must use a budget that was established and approved prior to March 27, 2020. Providers using 2020 budgeted patient care revenue to calculate the amount of lost revenues they may permissibly claim will be required to submit additional documentation at the time of reporting; or

c) calculated by any reasonable method of estimating revenue. If a recipient wishes to use an alternate reasonable methodology for calculating lost revenues attributable to coronavirus, the recipient must submit a description of the methodology, an explanation of why the methodology is reasonable, and establish how the identified lost revenues were in fact a loss attributable to coronavirus, as opposed to a loss caused by any other source. All recipients seeking to use an alternate methodology face an increased likelihood of an audit by HRSA. HRSA will notify a recipient if their proposed methodology is not reasonable, including because it does not establish with a reasonable certainty that claimed lost revenues were caused by coronavirus. If HRSA determines that a recipient’s proposed alternate methodology is not reasonable, the recipient must resubmit its report within 30 days of notification using either 2019 calendar year actual revenue or 2020 calendar year budgeted revenue to calculate lost revenues attributable to coronavirus.”

Providers who choose option (a) will be required to submit quarterly detail of their patient revenues by payer type. This does not change the previous guidance.

Option (b) will require submission of their 2020 budget and 2020 actual revenues with certification by the CEO or CFO that the budget was approved before March 27, 2020. The current guidance does not indicate if the data would be submitted by quarter or for the year.

All recipients seeking to use option (c) face an increased likelihood of an audit by HRSA.

Even with the delay in the reporting due date, providers should not wait until the last minute. Let us help you prepare so you can be ready. We can help in the registration process; use additional guided processes to help you identify, correctly allocate and report on appropriate expenses; and assess your internal controls’ compliance in preparation for the new deadline. Additionally, our fees can be part of an allocated expense for the use of Provider Relief Funds. 

Please contact Ron Present at 314.983.1358 or rpresent@bswllc.com or Mark Renken at 636.754.0234 or mrenken@bswllc.com.

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