This blog was written and produced by Margaret Lally and Robert Nasso, CPA at The Bonadio Group. Looking to get in touch with Margaret or Robert? Reach out today: Margaret Lally firstname.lastname@example.org, Robert Nasso email@example.com.
The highly-anticipated and often delayed HHS Provider Relief Fund Reporting Portal officially opened on July 1, 2021 here. Along with the portal itself, a user guide, an excel template workbook, and several new FAQs were also issued. These are in addition to updated reporting guidance that was released on June 11, 2021 here. These new resources clarified and resolved several important issues.
Reporting and Use of Funds Deadlines Extended
The deadlines to use HHS Provider Relief Funds and report on their use are now based on the date the funds were received. The below table shows the new deadlines as well as the distributions that could be included in each reporting period. Some distributions may have spanned multiple reporting periods, so providers should document the amount of funds received, the date of receipt, and the type of distribution. Previously, providers who received less than $10,000 in aggregate PRF distributions did not have to report on use of funds, providers receiving between $10,000 and $500,000 had to report expenses in 2 major categories (General & Administrative and Healthcare Related Expenses), and providers receiving more than $500,000 had to further breakout expenses into more detailed categories. The new guidance indicates that these limits are now applicable to each reporting period instead of in total.
The reporting portal will require several data elements that providers should begin to accumulate in preparation for the first reporting period deadline on September 30, 2021. The excel workbook provided on the portal site is a great resource that will help ensure all required data is prepared and in an easy format consistent with the portal. The following are the main items providers will need to collect:
- Interest earned on PRF payments – this interest can be used for eligible expenses.
- Other assistance received – PPP, FEMA, state COVID-19 assistance, business insurance, etc.
- Use of SNF and Nursing Home Infection Control Payments – these are now included in the same reporting process as General Distribution payments.
- Use of General and Other Targeted Distributions.
- Net Unreimbursed Expenses Attributable to Coronavirus – after PRF and other assistance is applied.
- Lost Revenues Reimbursement.
- Personnel, Patient, and Facility Metrics.
- Survey detailing how the payments impacted providers’ ability to maintain solvency, retain staff, prevent furlough, facilitate changes to operate during the pandemic, and care for and treat patients.
Clarification of Several Outstanding Issues
The release of the portal and accompanying FAQ cleared up several questions that were previously uncertain. A new FAQ confirms that PPP funds and any other monies reported in the “Other Assistance Received” section of the portal will NOT be used in the lost revenue calculation. Lost revenues can also be carried forward into subsequent reporting periods if not fully utilized in the current reporting period. Lost revenues will be reported by quarter and each quarter will stand alone so only quarters where revenue was lost will be totaled to determine the annual amount of lost revenue. This means that gains in one quarter will not count against providers!
For purchases of tangible items made using PRF payments, the purchase does not need to be in the provider’s possession to be considered an eligible expense, but the costs must be incurred before the deadline to use funds. Providers must follow their basis of accounting to determine expenses. This treatment may help providers who are considering a capital project but are concerned about the timing of completion.
The order of use of funds has been a complicated issue and the new FAQ shed some light on how providers should approach multiple funding streams. For example, if a provider has submitted an application to FEMA but has not yet received the FEMA funds, they should not report the requested FEMA amounts in the PRF reporting portal. If a provider receives FEMA funds retroactively covering a reporting period, they must not use them on expenses already covered by PRF. FQHCs and FQHC look-alikes must use COVID-19 supplemental grant awards before HHS PRF.
The reporting guidance contains a detailed list of expenses that are allowable for the Nursing Home Infection Control Distribution. Since lost revenues are not an allowable use of the Nursing Home Infection Control distributions and the eligible expenses are much more specific, providers should review to ensure they are able to retain the funds.
Providers must return unused funds to the government within 30 calendar days of the end of the applicable reporting period. No extensions for reporting or use of funds will be granted and providers who do not report will be deemed not in compliance with the terms and conditions and may be subject to recoupment.
Providers should register for the reporting portal if they have not already done so. The reporting portal user guide and accompanying excel workbooks should be reviewed along with the FAQ and Post-Payment Notice of Reporting Requirements. Providers should begin to accumulate the data necessary to be prepared for the first reporting period deadline of September 30, 2021. Please feel free to reach out with questions or requests for assistance!
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.