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, mlally@bonadio.com.
On January 15, 2021, HHS opened the reporting portal for the Provider Relief Fund. In a departure from previous announcements, it is only open for provider registration and not actual reporting. Providers are encouraged to register if they have received HHS Provider Relief Funds. HHS indicates that reporting on the use of funds will be delayed but has not announced what the new deadline will be. HHS also states that they will hold webinars to go over the reporting process in detail and answer questions.
A separate registration is required for each reporting entity and registration will take about 20 minutes. Providers must complete the registration in one session as they are not permitted to save and return later and cannot make any changes once the registration is submitted. Registration requires the following information:
- Tax ID Number
- Business Name (as it appears on the W-9)
- Contact information (name, phone, email) – this can be duplicated across entities if one person is responsible for multiple entities
- Address
- TINs of subsidiaries if entity is reporting on subsidiaries
- Payment information for any 1 payment received
- TIN of entity receiving payment
- Payment Amount
- Mode of Payment (check or ACH)
- Check number or ACH settlement date
The username should be an email address but must be unique for each entity. The contact email will receive all updates and can be duplicated among entities. Providers who received the SNF Infection Control Distribution are subject to separate reporting requirements that have not yet been released but should still register in the reporting portal. There is a user guide and FAQ on the HHS Provider Relief Fund website.
The post-payment reporting requirements on the site were also revised to incorporate the updates legislated in the Coronavirus Response and Relief Supplemental Appropriations Act of 2021. There are now three allowable methods to calculate lost revenue: comparing 2019 actual patient revenue to 2020 actual patient revenue, the difference between 2020 budgeted patient revenue and actual 2020 patient revenue, and a third method allowing “any reasonable method of estimating revenue”. This last method must be accompanied by a description of the calculation and methodology and an explanation for why it is reasonable and establishes the loss is attributable to coronavirus. The budget method may be advantageous for providers whose 2019 revenue is not reflective of their 2020 revenue. For example, providers who added or dropped a service line, or had a change in rate unrelated to coronavirus may find the budget method results in a more accurate representation of the effect of coronavirus on revenue.
The COVID Relief bill provided additional flexibility in permitting Targeted Distributions to be moved among subsidiaries, but the new guidance indicates that these transfers will be scrutinized more closely than transfers of General Distributions. The language around allowable expenses has also been updated. Previously expenses incurred in “maintaining healthcare delivery capacity which includes operating and maintaining facilities” were allowable, but that language has been removed. The new footnote reads “Expenses attributable to coronavirus may be incurred in both direct patient care and overhead activities related to preventing, preparing for, and responding to coronavirus.” The words “attributable to coronavirus” were also added in several places. This comports with more recent FAQs that have focused more on incremental expenses related to coronavirus than on the previous expansive definitions of allowable G&A expense.
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.