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Update on Provider Relief Fund Reporting Requirements

As part of the terms and conditions of accepting Provider Relief Fund (PRF) payments, providers who received payments exceeding $10k in aggregate must comply with the reporting requirements established by the Health Resource and Services Administration (HRSA). As part of this requirement, providers will report their use of PRF payments to ensure proper use of funds in adherence with the established guidelines. 

The PRF was established to reimburse healthcare providers for healthcare related expenses or lost revenues attributable to coronavirus. As such, below are two of the main financial data elements that will ultimately need to be submitted as part of the reporting process:

  1. Healthcare related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse, which includes General and Administrative (G&A) and/or other healthcare related expenses.
  2. PRF payment amounts not fully expended on healthcare related expenses attributable to coronavirus are then applied to patient care lost revenues. There are multiple methods available to calculate patient care lost revenue.

In addition to the two main elements listed above, other data elements that might be required include:

  1. Basic organization data (EIN, tax classification, employee and facility data, etc.)
  2. Other assistance received in 2020, including business insurance, PPP loans, state/local assistance, etc.
  3. Billing reports showing revenue by patient care payor mix, net charges from patient care
  4. For providers who received over $500k in aggregate PRF payments, additional expense information must be provided for high-level expense categories, including mortgage/rent, personnel, supplies, equipment, etc.
  5. Providers who expended $750k or more in aggregated federal financial assistance during their fiscal year (including PRF payments and other federal financial assistance) will be subject to the Single Audit requirements. Please note, PPP loans are not considered federal financial assistance.

Originally, the reporting period was scheduled to open on 1/15/2021, and providers would have one month, until 2/15/2021 to submit all their information. Any providers who could not show proper use of 100% of their PRF payments by 12/31 would have an additional six months to use the funds and would submit an additional set of data by 7/31/2021. However, due to the passage of the Coronavirus Response and Relief Supplemental Appropriations Act in late December, HHS announced on 1/15/2021 they were amending and delaying the reporting timeline for PRF payments. At this time, no updated timeline has been announced.

Although the reporting period has been delayed, providers can still register for, and establish their reporting account. When the reporting period does open, it will likely be a small window of time, so we are recommending providers set up their account ahead of time. This process can be completed on the HRSA website HHS estimates the registration process will take around 20 minutes to complete and must be completed in one session. 

Here at YHB, we are closely monitoring the guidelines surrounding the reporting requirements and will keep you up-to-date as more information is released. 

If you have any questions regarding the upcoming reporting requirements, don’t hesitate to contact your advisor.

About the Author

Justin Bryan, CPA

Since joining the firm Justin has specialized in tax and consulting services for individuals and businesses while supporting the YHB Healthcare Team. Justin is a member of the American Institute of Certified Public Accountants (AICPA), Virginia Society of Certified Public Accountants (VSCPA) and National CPA Health Care Advisors Association (HCAA).