Provider Relief Fund Reporting — Are You Ready?
In September, the Department of Health and Human Services (HHS) published guidance on the reporting requirements for recipients of Provider Relief Funds (PRF). This guidance was updated on October 22.
In this article series, we will review the important information we know now and keep you informed as new information becomes available.
What We Know Now
Based on the latest guidance, what we know now is:
- Providers who have received under $10,000 are not required to report.
- Providers that received over $10,000 but less than $500,000 can submit summary reports.
- Providers that received over $500,000 but less than $750,000 will need to submit more detailed reports.
- Providers that received over $750,000 will need to submit single audit reports.
This series will focus on those providers who have received over the $10,000 limit, but less than $750,000 from the Phase I and Phase II General Distributions (reporting requirements for Nursing Home Infection Control and the Rural Health Clinic Testing Distributions are different). These providers represent 93.5 percent of the recipients required to report.
Here are a few facts about the recipients who have received and attested to PRF payments as of October 20, 2020:
|Payment Range||Number of Providers||Total Dollars|
|Less than $10,000||188,671||$.5 Billion|
|Between $10M and $500M||156,777||$10.6 Billion|
|Between $500M and $750M||6,129||$3.8 Billion|
|Greater than $750M||11,263||$80.0 Billion|
While the final reporting formats have not been released, providers should now be tracking and documenting PRF receipts and other funding awards received. Providers will be required, as part of their PRF reporting, to submit all other assistance they have received including Payroll Protection and other SBA loans, FEMA, CARES Act COVID-19 testing receipts, other local and state assistance, and business interruption insurance. Notably, the FAQs released October 28 indicate that any increased insurance reimbursement that a provider received during the pandemic is considered “other assistance.” For example, if a commercial insurer increased reimbursement specifically due to the pandemic, these payments would need to be included as “other assistance.”
The first reporting element for the PRF is the actual health-care-related expenses attributable to COVID-19. Providers will report their expenses in two general categories: general and administrative expenses, and health-care-related expenses. Both categories are to be reported net of expenses covered by other programs, such as PPP loans and FEMA grants.
The General and Administrative Expenses Attributable to Coronavirus include:
- Personnel (limited to $197,300 annually)
- Fringe Benefits (for all employees)
- Lease Payments
- Other G&A expenses (not captured above)
The Healthcare-Related Expenses Attributable to Coronavirus include:
- Equipment (the FAQs limit this to the depreciation amount)
- IT Expenses
- Facilities (At this point, these improvements are not limited to the depreciation amount)
- Other Healthcare Related Expenses (not captured above)
As pointed out above, while the reporting forms have not been released, providers should maintain receipt-level detail for all additional expenses incurred as a result of COVID-19. As part of the reporting guidance, providers will be required to submit total calendar year expenses, with a quarterly breakdown, for calendar year 2019 and 2020. These will need to be submitted in the same G & A and healthcare-related expense categories described above. This may require a review of a provider’s general ledger reporting system.
We further recommend that receipt-level detail be documented for all capital expenditures related to COVID-19 as these are eligible expenses but will be depreciated for reporting purposes. The same will apply to facility improvements.
In the expense tracking, it is important that providers coordinate the use of funds from all sources when reporting the PRF expenses. For example, employee salaries forgiven as part of PPP loan forgiveness are not eligible expenses for PRF purposes.
Fluid and Complicated Guidelines
It is critical for all providers to keep up to date with HHS guidelines. These are fluid and may change daily. For example, on October 8, HHS sent a Medicare Learning Network email indicating that providers could use their PRF funds to repay their Medicare Accelerated and Advance Payments (an eligible expense). On October 9, HHS reversed this position and said the Accelerated and Advance Payments is not an eligible use of PRF payments.
Are You Ready?
The Brown Smith Wallace Health Care team is ready to help you prepare for the Provider Relief Fund reporting requirements. Please contact Ron Present at 314.983.1358 or firstname.lastname@example.org or Mark Renken at 636.754.0234 or email@example.com.