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Provider Relief Fund: How to Report Equipment and Facility Costs − Are You Ready?

12.04.2020

Since our last article, HHS has not issued any updates to their FAQ document. However, we do want to emphasize the important change regarding equipment and facility costs incurred due to coronavirus.

In their initial guidance, HHS said that providers could only report the depreciation amount incurred for equipment and facility costs due to COVID-19. On November 18, HHS changed its position. Based on the new FAQ guidance, HHS’s position is now:

“Expenses for capital equipment and inventory may be fully expensed only in cases where the purchase was directly related to prevent, prepare for and respond to the coronavirus. Examples of these types of equipment and inventory expenses include:

  • Ventilators, computerized tomography scanners, and other intensive care unit- (ICU) related equipment put into immediate use or held in inventory
  • Masks, face shields, gloves, gowns
  • Biohazard suits
  • General personal protective equipment
  • Disinfectant supplies

Expenses for capital facilities may be fully expensed only in cases where the purchase was directly related to preventing, preparing for and responding to the coronavirus. Examples of these types of facilities projects include:

  • Upgrading a heating, ventilation, and air conditioning (HVAC) system to support negative pressure units
  • Retrofitting a COVID-19 unit
  • Enhancing or reconfiguring ICU capabilities
  • Leasing or purchasing a temporary structure to screen and/or treat patients
  • Leasing a permanent facility to increase hospital or nursing home capacity”

As part of the reporting process, providers will also be required to submit non-financial data (per quarter). These include: Personnel Metrics, Patient Metrics, Facility Metrics. As of now, it appears this data will be submitted for 2020. The FAQs clarified the categories for classifying personnel. The categories are:

  1. Full-time: personnel employed on average 30 hours of service per week, or 130 hours for a calendar month.
  2. Part-time: personnel employed any time between 1 and 34 hours per week, whom may or may not qualify for benefits.
  3. New hires: personnel not previously employed by the employer; or previously employed but voluntarily or involuntarily separated for at least 60 consecutive days.
  4. Re-hires: personnel that left a company due to voluntary or involuntary separation and are brought back to work by employer.
  5. Voluntary separation: personnel voluntarily submits a written or verbal notice of resignation.
  6. Involuntary separation: management decides to terminate its relationship with an employee because of either economic necessity or poor fit; includes lay-offs and expired contracts.
  7. Furloughed: when a staff member involuntarily takes unpaid leave of absences.
  8. Leave of Absence: personnel voluntarily take an extended period of time away from work while still maintaining their employee status; can be paid or unpaid.

Fluid and Complicated Guidelines

It is critical for providers to keep up to date with HHS guidelines. Even though HHS has not issued the final reporting documents, the reporting portal is scheduled to open on January 15, 2021, and the first report is due February 15, 2021, for any provider who received over $10,000 but less than $750,000. If you received at least $750,000, separate reporting regulations, including a single audit, are required.

Providers should be gathering all the expense, lost revenue and non-financial data to be prepared. Remember, any PRF funds received that are not spent on increased expenses or lost revenues due to coronavirus will need to be returned to HHS. For providers who operate on a calendar year basis, any re-payment will affect their year-end financial reporting.

Are You Ready?

Providers should not wait until the last minute. Let us help you prepare so you can be ready. We use guided processes to help you identify, correctly allocate and report on appropriate expenses in preparation for the February 15, 2021, 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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