This article was written and produced by Robert Nasso, Partner, and Margaret Lally, Healthcare Consulting Manager. Looking to get in touch with Robert or Margaret? Reach out today: rnasso@Bonadio.com, firstname.lastname@example.org.
On September 19, HHS released the long-awaited data elements and reporting requirements that will be required as part of the post-payment reporting process announced in July and revised on August 14th. Providers should specifically review the updated lost revenue calculation as it has changed significantly from prior guidance and places limits on the use of payments as an offset to lost revenue.
Post-Payment Reporting Requirements
Providers who received Provider Relief Funds (PRF) of more than $10,000 in aggregate will need to report on the expenses and lost revenue attributable to coronavirus. The data elements announced are applicable to all distributions except the Nursing Home Infection Control distribution (received in late August) and the Rural Health Clinic testing distribution. Reporting elements for these distributions will be released in the future. Providers must submit data for 2019 and 2020 as follows:
The use of Provider Relief Fund payments will be reported by submitting healthcare-related expenses attributable to coronavirus that have not been reimbursed through another source. As previously laid out in the terms and conditions, expenses must be associated with the treatment of confirmed or suspected cases of coronavirus, preparing for possible or actual coronavirus cases, or maintaining healthcare delivery capacity which includes operating and maintaining facilities.
Expenses are separated into two main categories: healthcare-related operating expenses and general and administrative expenses. Entities receiving between $10,000 and $499,999 in aggregated PRF funds will report expenses in aggregate by category and by quarter. Providers receiving $500,000 or more in PRF funds will be required to break out each category in greater detail:
1. General and Administrative Expenses
- Fringe Benefits
- Lease Payments
- Other General and Administrative
2. Healthcare Related Expenses
- Information Technology
- Other Healthcare Related Expense
If not all PRF funds are expended through expense, the lost revenues calculation will apply. The definition of lost revenue has changed from the guidance in the FAQ. It is now calculated as the change in “year-over-year net patient care operating income” which is further specified as:
Patient Care Income – Patient Care Related Expenses
HHS also appears to have put a cap on the amount of lost revenues allowable which is now limited to either:
- The amount of a providers 2019 net gain from healthcare-related sources.
- If there was a loss in 2019, lost revenues can be applied up to a net-zero gain in 2020.
Calendar year revenue from patient care, net of bad debt, will be entered by quarter for 2019 and 2020 and broken out by payer. Providers will also need to report on other assistance received such as PPP funds, FEMA grants, state and local government dollars, business insurance proceeds, and other assistance.
Other Data to be Collected
HHS will also collect the following data through the online reporting tool:
1. Personnel Metrics - Total personnel by full-time, part-time, contracted, other and total re-hires, total new hires, total separations
2. Patient Metrics - Number of patient visits, number of admissions, number of residents
3. Facility Metrics - Available staffed beds for medical/surgical, critical care, and other
4. Change in Ownership – Date, TINs, % of ownership, and controlling interest in the acquisition/divestiture
- October 1 – Date that the online reporting system was scheduled to go live. This has now been delayed until “early 2021”.
- February 15, 2021 – Due date for online reporting of 2020 expenses and lost revenue. If all funds are expended in 2020, this is considered the final report.
- June 30, 2021 – Current deadline to expend funds.
- July 31, 2021 – Due date for online reporting of 2021 expenses and lost revenue.
HHS confirmed that providers receiving more than $750,000 in federal awards will be subject to single audit requirements. Audit reports must be submitted to the Federal Audit Clearinghouse.
If you have questions or need additional assistance, please feel free to reach out to us.
The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We, therefore, make no warranties, expressed or implied, on the services provided hereunder.