Reporting Requirements for Provider Relief Fund

On September 19, 2020, HHS released its first guidance document on reporting requirements for recipients of the Provider Relief Fund based on the CARES Act. Providers who have received more than $10,000 in the aggregate from the Provider Relief Fund are required to report data elements to HRSA.  Importantly, the reporting system opening date has been delayed from October 1 to “early 2021”. Advis has summarized the reporting requirements below.

In its guidance, HHS broadly defines the types of expenses that are covered, including both confirmed and suspected COVID-19 cases, in addition to several operating expense categories. HHS also specified that lost revenue would be defined as a year-over-year comparison of 2019 compared to 2020.

It is anticipated that HHS will release future clarifying guidance documents, FAQs, and informational webinars to address outstanding questions. Of note, the guidance document suggests that funds must be first applied toward non-reimbursed expenses and then to lost revenue. The guidance also appears to suggest that providers may first apply to FEMA or other sources to obtain reimbursement for a portion of eligible expenses, and thereafter allocate any balance of these expenses and lost revenues to CARES PRF funds.

For questions regarding the Provider Relief Fund reporting requirements or other inquiries related to the CARES Act, FEMA, or COVID-19, reach out to one of Advis’s COVID-19 Task Force members.

Overview

• Funds may be used for healthcare related expenses and lost revenues.
  • Expenses: Includes “General and Administrative” expenses and healthcare operating expenses that have not been reimbursed, or are obligated to be reimbursed, by another source. Expenses may include treating both confirmed or suspected cases of COVID-19, preparing for possible or actual COVID-19 cases, maintaining healthcare delivery capacity, etc.
  • Lost Revenue: Defined as “negative year-over-year net patient care operating income”.
    • Funds for lost revenue may be applied up to the amount of 2019 net gain from healthcare related sources.
  • All funds must be used by June 30, 2021.
  • All funds must be reported no later than July 31, 2021.

Data to be Reported

• Demographic Information: 
  • Reporting Entity: Entity that received one or more PRF payments. The Reporting Entity may report on behalf of subsidiary entities that received payments unless the subsidiary entity received a Targeted Payment
  • TIN of Reporting Entity
  • NPI (optional)
  • Fiscal Year-End Date
  • Federal Tax Classification
• Expenses (for 2019 and 2020, with quarterly breakdown):
  • If received $10,000-$499,999 in aggregated payments: Report expenses in two aggregated categories: (1) General and Administrative (G&A) expenses, and (2) other healthcare related expenses.
  • If received $500,000 or more in aggregated payments: Report expenses in the two aggregated categories (G&A expenses and other healthcare related expenses), in addition to the following subcategories:
    • General & Administrative Expenses:
      • Mortgage/Rent
      • Insurance
      • Personnel
      • Fringe Benefits
      • Lease Payments
      • Utilities/Operations (e.g. lighting, cooling, cleaning, vendor services not included in Personnel)
      • Other General and Administrative Expenses (other expenses considered part of overhead)
    • Other Healthcare Related Expenses:  
      • Supplies (e.g. PPE, hand sanitizer)
      • Equipment (e.g. ventilators, HVAC)
      • IT (e.g. telehealth infrastructure, teleworking, increased bandwidth)
      • Facilities (e.g. lease/purchase of permanent or temporary structures, modifications to facilities)
      • Other Healthcare Related Expenses (other expenses paid to prevent, prepare for, or respond to COVID-19)
• Lost Revenue: 
  • Total revenue/net charges from patient care related sources (2019 and 2020): Lost revenue will be calculated based on a calendar year comparison of 2019 and 2020 net operating income. Revenue/net charges from patient care (i.e. excluding uncollectable patient service revenue recognized as bad debts) will be reported prior to netting with expenses. Revenues will be entered by quarter (e.g. Jan-March 2019, April-June 2019).
    • Patient care means health care, services and supports, as provided in a medical setting, at home, or in the community. It should not include: 1) insurance, retail, or real estate values (except for SNFs, where that is allowable as a patient care cost), or 2) grants or tuition.
    • Revenue from Patient Care Payer Mix (2019 and 2020)  
      • • Medicare Part A+B: The actual revenues/net charges received from Medicare Part A+B for patient care for the calendar year.
        • Medicare Part C: The actual revenues/net charges received from Medicare Part C for patient care for the calendar year.
        • Medicaid: The actual revenues/net charges received from Medicaid/Children’s Health Insurance Program (CHIP) for patient care for the calendar year.
        • Commercial Insurance: The actual revenues/net charges from commercial payers for patient care for the calendar year.
        • Self-Pay (No Insurance): The actual revenues/net charges received from self-pay patients, including the uninsured or individuals without insurance who bear the burden of paying for healthcare themselves, for the calendar year.
        • Other: The actual gross revenues/net charges from other sources received for patient care services and not included in the list above for the calendar year.
    • Other Assistance Received (2020)
      • • Treasury, Small Business Association, and the Paycheck Protection Program: Total amount received as of reporting period end date.
        • FEMA CARES Act: Total amount received from FEMA by the Reporting Entity as of the reporting period end date.
        • CARES Act Testing: Total amount received from HHS for coronavirus testing-related activities.
        • Local, State, and Tribal Government Assistance: Total amount received from other Local, State, or Tribal government sources by the recipient and its included subsidiaries as of the reporting period end date.
        • Business Insurance: Paid claims against insurance policies intended to cover losses related to healthcare business interruption as of the reporting period end date.
        • Other Assistance: Total amount of other federal and/or coronavirus-related assistance received by the recipient and the other TINs included in its report as of the reporting period end date.
    • Total Calendar Year Expenses for 2019 and 2020, in the following categories, with quarterly break down:
      • • G&A Expenses (2019 and 2020): May include items such as monthly mortgage/rent payments for facility where reporting entity provides patient care services, other monthly finance charges for real property and/or property taxes, insurance premiums for property, employee health insurance, or malpractice insurance, overhead salaries, healthcare and contractor salaries, fringe benefits, lease payments, lighting, cooling/ventilation, cleaning, vendor services purchased from third party vendors, consulting support, legal fees, audit and accounting services, food preparation and supplies, logistics and transport or other costs not captured above, such as debt financing, for the relevant calendar year.
        • Healthcare Related Expenses (2019 and 2020): May include items such as supplies, equipment, IT, facilities, employees, and other healthcare related costs/expenses for relevant calendar year.
    • Additional non-financial data (per quarter):
      • • Facility, Staffing and Patient Care
          • Personnel Metrics: Total personnel by labor category (full-time, part-time, contract, other), total re-hires, total new hires, total personnel separations by labor category.
          • Patient Metrics: Total number of patient visits (in-person or telehealth), total number of patients admitted, total number of resident patients.
          • Facility Metrics: Total available staffed beds for medical/surgical, critical care, and other beds.
        • Single Audit Status: Recipients must indicate if they are subject to Single Audit requirements in 2020, and if yes, whether the auditors selected PRF payments to be within the scope of the Single Audit (if known at the time the Reporting Entity submits report).
        • If Reporting Entity underwent a Change in Ownership, it must provide:
          • Date of acquisition/divestiture
          • TIN(s) included in the acquisition/divestiture
          • Percent of ownership for acquisition/divestiture
          • Did/do you hold a controlling interest in this entity? (Y/N)

For more information, please contact the experts at Advis online or by calling 708-478-7030.

Published: September 20, 2020